I have a related question. We just received a request to fill out a small business subcontracting plan from a prime. We're not subcontracting any of the work. We're doing it all. Are we required to fill out this information and report it? There are a lot of stipulations.

The answer is that a subcontractor is not required to submit anything to a government agency unless the government agency requires it at the time that you submit your offer. The Sub is obligated to you, not the agency.

The requirement for Subcontracting Plan is in PL- 95-507 as a small business, prime contractor, you are NOT required to submit a Subcontracting Plan and none of your subcontractors, whether small or large, are required to submit a Subcontractor Plan. The short answer is only Large Businesses, acting as the prime contractor, for contracts equal or exceeding $500K are required to have an approved Subcontracting Plan before award. Good luck! Bill

gt - First, I apologize for not getting an answer to your initial question. We strive to answer all posts in a timely manner but occasionally one escapes us. After some research, I haven't found a resource that confirms whether or not a large sub would need to submit a subcontracting plan, but I've extended the question to some our industry experts and hopefully they can chime in with some details. In the meantime, have you asked your COTR if this is a required step for your sub?

Based upon my 20 years as a federal contractor, the answer is NO. The sub of a small business may be a big business but it is not then required to submit a subcontracting plan. The obligation only goes to the prime. Jos A. Rivera, J.D. President & CEO Rivera, Sierra & Company, Inc.

Mr. Rivera, Thank you for your response. gt

Nicole, Thank you for following up. I don't know if you triggered Mr. Rivera's response, but it is the answer I was looking for. gt