Federal Contracts/Federal Grants With Required Small Business Plans

Questions? Contact SCM Response Team

Overview

Certain federal contracts and grants require Small Business Plans. 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 Procurement team to document, prepare, and submit the Small Business Plan. 

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:

  1. 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.
  2. 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 prime company.
  3. 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 Contracting Plans from any such institutions.

If you have questions concerning an award application or existing Small Business Plan, contact Marliz Copado.

Roles and Responsibilities

SCM Procurement, in conjunction with Office of Sponsored Research, and Contracts and Grants Administration 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 Chief Accounting Officer or Departmental Financial Analyst.