Comment on FR Doc # 2011-30927

Document ID: SBA-2011-0009-0034
Document Type: Public Submission
Agency: Small Business Administration
Received Date: December 13 2011, at 12:00 AM Eastern Standard Time
Date Posted: December 21 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: December 1 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: January 6 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 80f81e6a
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This is comment on Proposed Rule

Small Business Subcontracting

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Proposed Solution: Transparency for Subcontracting Plans Small Business Subcontracting Plans are agreements reached between large business prime contractors and Federal contracting officers. These agreements may establish goals and programs at a corporate level or they may be focused on one specific contract. Either way, they represent commitments by executives of large businesses that they will work diligently to include small businesses of all types as suppliers and subcontractors for products and services used in the performance of government contracts. Unfortunately, once these agreements are signed, they disappear into the file. No provision has been made for public transparency of the large business’ goals or anticipated methods for achieving the goals, nor for measurement of progress against those goals. By providing public disclosure of the goals and progress, there would be more of a commitment to achieve the goals. Furthermore, small businesses would be able to determine their best strategies for marketing their capabilities, focusing on those primes who need subs with their skill sets. This would save time and effort for both the large and small businesses, as small businesses would avoid wasting their time and the large business SBLO’s time if the prime is already meeting its goals. Another positive impact of transparency would come from contracting officers being able to see the provisions of plans for other contracts and the prime’s progress in meeting its stated goals. This information also then becomes available for evaluating past performance. With the current administration’s focus on transparency, applying that tenet to subcontracting plans is a natural. At the time an award is posted to FPDC, the contracting office should also post the prime’s SB goals for the contract. (If the plan establishes corporatewide goals, a different approach would need to be developed.) The goals data could then be extracted from the FPDC submission into a Subcontr

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