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SBAs Post Award Subcontract Reform and Enforcement Introductions SBAs Angela Angela.Terry Subcontracting Terry @ Program Manager sba.gov Your Compliance Cheerleader 2 Understanding Subcontracting Reform and Enforcement


  1. SBA’s Post Award Subcontract Reform and Enforcement

  2. Introductions SBA’s Angela Angela.Terry Subcontracting Terry @ Program Manager sba.gov Your Compliance Cheerleader 2

  3. Understanding Subcontracting Reform and Enforcement • Why Subcontract Reform • SBA’s Post Award Subcontracting Program’s Reform Focus • The Benefit of Subcontract Reform • Why Subcontract Enforcement • SBA’s Post Award Subcontracting Program’s Enforcement Focus • The Benefit of Subcontract Enforcement • Assistance with Post Award Subcontract Compliance • Become Familiar

  4. Why Subcontract Reform To create uniform processes and procedures, provide accurate regulation interpretation, provide 24hr training and support opportunities, make processes and procedures transparent, and provide efficient and effective methods of communication, to make Compliance Reviews (CR) a priority and perform CR on all contracts indicated in the 4 Small Business Act.

  5. SBA’s Post Award Subcontracting Program’s Reform Focus Pre and Post Subcontracting responsibilities and ✔ requirements ✔ Post Award Support Program ✔ Removed Geographical Barriers ✔ Share CR information and rating with the awarding agency ✔ Transparency Accurate interpretation of ✔ Federal Regulation ✔ Compliance Reviews ✔ Uniform Processes and Procedures 5

  6. Benefits of SBA’s Subcontract Post Award Reform Understand how to perform Subcontract requirements Compliance Training available to all Increase of Compliance Build capacity and grow Reviews (CR) Increase in compliance 24 hour/7days a week Subcontract Assistance via training videos and guides 6

  7. Why Subcontract Enforcement Pursuant to the Small Business Act, SBA provides oversight of the Subcontracting Program to ensure implementation, management, adherence, and compliance with the laws, regulations, processes and procedures. 7

  8. SBA’s Post Award Subcontracting Program’s Enforcement Focus CR on contracts required by the Small ✔ Business Act SB Subcontract Reporting ✔ SB receiving subcontract ✔ opportunities Awareness and understanding ✔ Of SB Subcontract regulation, process and procedure ✔ SB Subcontracting Past Performance Rating ✔ Accuracy of information in FPDS-ng 8

  9. Benefits of SBA’s Subcontract Post Award Requirement Enforcement Ensures awareness Ensures SB receive Subcontract Opportunities Ensures adherence to regulations, processes and Build capacity and grow procedures Ensures identification of eligible contracts Ensures accurate documentation of SB Subcontract Past Performance 9

  10. Assistance with Post Award Subcontract Compliance available January 2020 Subcontract Compliance Guide FAQ Bi-Weekly Prime and Sub-contractor Subcontract Training Hour Bi-Weekly SB Subcontractor Training Hour SOAR Video Training 10

  11. Become Familiar Federal Procurement Data System (FPDS-NG 1 Federal Contract Award Data • Obtain a listing of contracts issued afuer May 2015 with the inactive Subcontract Plan type codes and make the necessary corrections • Obtain a listing of contracts eligible for CR and track compliance Subcontract Reporting and Review Compliance 2 Identify what reports have not been • submitted Don’t forget to file your 1 st and final • subcontract report Verify what reports have been submitted • Verify what reports have not been reviewed • Obtain your SB Subcontract Plan Goals • 3 Advertise SB Subcontracting Opportunities • SubNet 11 • DSBS

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