Peggy, are you suggesting that the requirement for a "subcontracting plan" be extended to small businesses? Just curious, would you advocate applying that factor and an evaluation of it to small business offerors? Right now, it is only a large business requirement. Small Businesses are not required to submit a subcontracting plan.

There is a separate, recent DFARS requirement to evaluate ALL OFFEROR's - large or small - past performance in subcontracting to small, small disadvantaged, etc. (By the way, this is reported to be very difficult for small businesses to submit meaningful past performance data, because they've not been required to keep such data.) Happy Sails! Joel

By Peggy Richter on Monday, August 7, 2000 - 01:05 pm:

I may be missing something here, but it seems to
me that the intent of the Small Business program is to encourage SB. Thus, if a SB proposes, they are, by definition, using a SB (themselves). The rule is that a SB performs at least a "substantial" amount of the work - they may not be a simple "pass-thru" front. Therefore it seems to me that in evaluating contractors as to performance regarding Small Business participation, the logical thing to do would be to include the PRIME'S % if the prime happens to be a SB. This at least has the virtue of dealing with everyone equally. if X% of the work is SB effort (prime or subcontractor or combination of the two), it is X% regardless of if the award was to a large or small business. As to "subcontracting plans", the small business presumably has proposed to perform some % of the work "in house". this can be taken as the minimal SB effort the contractor is proposing. If they are ALSO subcontracting to OTHER SBs, they will likely be delighted to so inform the Govt if by doing so they will earn higher evaluation ratings.

Sorry, again. I was referring to a "point" scoring system in my last note! Full "points" would be awarded to a small business or to a large business which shows acceptable past performance in meeting its contractual obligations... Happy Sails!

Mary, I forgot to add that you could also devise a scoring system, applicable only to the subfactors for the "subcontracting plan" and "past performance in subcontracting to SB/SDB".

In this case, for example, "full score" would apply for "acceptable" subcontracting plan subfactor and for the past performance in subcontracting to SB/SDB subfactor. Happy Sails joel

By joel hoffman on Thursday, August 3, 2000 - 03:43 pm:

Mary: I believe that it is permissible to evaluate the past performance subfactor using a go/no go (e.g., acceptable/ marginal/unacceptable) rating system, applicable specifically to that subfactor.

Thus, a small business, not subject to the requirement to submit a subcontracting plan, is presumed to be "acceptable" for both the subcontracting plan and for past performance in meeting the goals in the (non-existent) subcontracting plan.

A large business can be downgraded for poor past performance in subcontract, a requirement contractually applicable to large business.....

This type system would not "favor" small businesses over large businesses which met their contractual obligations.

For several years, I evaluated small business subcontract plans using the AFARS numerical scoring system to determine a final evaluation rating, using a similar go/no-go system. The numerical system is used, in conjunction with other go/no-go crieteria, to detrmine whether the subcontracting plan is acceptable or, marginal with corrections, or unacceptable.

I don't see why you can't use a similar go/no-go system to evaluate past performance for subcontracting to small and small-disadvantaged businesses. As you probably know, you don't have to use the same "rating" system for every subfactor in a solicitation. You can tailor different rating systems to specific subfactors. Just be sure to explain the various systems in the RFP.

Hope that satisfies both your questions. Happy Sails! Joel

By Mary Raymundo on Thursday, August 3, 2000 - 01:58 pm:

Re: FAC 97-19. FAR Part 15.305 now says to structure solicitations so as to give offers from small business concerns the highest rating for the evaluation factors in 15.304(c)(3)(iii) and (c)(5). (c)(3)(iii) deals with evaluating the extent to which the offeror attained applicable goals for SB participation under contracts that required subcontracting plans. Currently, I look at a SB's past record of subcontracting to other small businesses. (c)(5) deals with evaluating proposed small business subcontracting participation in the subcontracting plan. Again, I currently look at the SB's list of proposed subcontractor's - but an actual subcontracting plan is not required from an SB. My question to you is: How do we structure these factors to be able to give SB's the highest rating for these items? My other question - no answer expected - is what happened to being fair and using procurement integrity.