Overview
Federal contracts may require a Small Business Subcontracting Plan. A Small Business Plan outlines how research teams will spend a portion of their award with certified small businesses. Principal Investigators must engage with the SCM Small Business Office team to document, prepare, and submit the Small Business Plan.
Updated Inflation-Adjusted Acquisition Thresholds
New inflation-adjusted acquisition thresholds will take effect on October 1, 2025.
What Changed?
The prime contractor subcontracting plan (FAR 19.702) threshold is increasing from $750,000 to $900,000.
What This Means for You
Submit your Small Business Plan as normal. There will be no changes to the Small Business Plan process.
Small Business Plan Triggers
When UCSF is awarded more than $750,000 in federal funding, it is required to submit a Small Business Subcontracting Plan in conjunction with the award agreement. Once a contract is awarded, the Plan is a binding document. The PI is responsible for meeting the spending requirements of the Plan throughout the duration of the contract.
The following situations trigger the requirement:
- A federal agency directly awards a prime contract to the University. That agency requires a Small Business Subcontracting Plan be submitted to the agency, either as part of the initial proposal package or after the award agreement has been initiated.
- Another institution or company is a prime contractor to a federal agency and awards a subcontract exceeding $750,000 to the University. UC San Francisco must submit and have a Small Business Subcontracting Plan approved, before an award agreement can be finalized between UCSF and the prime contract institution or federal agency.
- Another institution is a subcontractor to another prime contractor and initiates a subcontract with the University. The University must submit a plan to that subcontractor.
If the UCSF is the prime contractor, and in its proposal, includes subcontracts to other institutions (called "flow down" as required by FARS 52.219-9), it must also obtain and approve Small Business Subcontracting Plans from any such institutions.
If you have questions concerning an award application or existing Small Subcontracting Business Plan, contact Marliz Copado.
Roles and Responsibilities
Supply Chain Management (SCM) Small and Local Business Office, in conjunction with Office of Sponsored Research (OSR), and Contracts, Grants, and Accounting (CGA) maintains a Standard Operating Procedure for Federal Contracts Requiring A Small Business Plan. This document outlines the roles and responsibilities for all parties involved in the plan writing process and the ongoing assessment of spending for the extent of the contract.
For additional help with budgeting and award spend management, Principal Investigators should engage with their Finance, Accounting, and/or Program Manager or Analyst.