Federal Contracts/Grants and Small Business Subcontracting Plans

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. 

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.

 For more information, visit Campus Supplier Diversity and Inclusion Program. If you have questions concerning an award agreement, contact Marliz Copado.

In the event a federally funded project is not able to spend with a small business for which it included goals in a Small Business Subcontracting Plan, the Principal Investigator/project team must provide documentation outlining reason(s) spend could not occur during a federal reporting period and describe the efforts that will be made to purchase from that business in the future. This information needs to be shared with the person filing Individual Subcontracting Reports (ISR) in the Electronic Subcontracting Reporting System. 

If spend will not occur at all with the business, explain the reason why in writing and document the name of an alternate small business to provide the goods or services.  If another small business cannot be used, document why, and the name of the large business from which the goods or services will be purchased. The PI/Project Team must then contact the Contracting Officer to explain the situation. 

THE PRINCIPAL INVESTIGATOR

Coordinates with the Supply Chain Management (SCM), the Research Administrator, and the project team to determine how the project can best meet the small business utilization goals. Provides funding documentation to SCM:

1. A copy of the proposal to the funding organization, including the Statement of Work

2. An accurate summary budget including the following line items:

1. Materials and supplies
2. Equipment
3. Travel
4. Services from an outside supplier

3. Preparation of the Small Business Subcontracting Plan Worksheet - includes descriptions and dollar amounts for materials and supplies, equipment costing more than $5,000, travel, and services to be purchased from small businesses. In the event the funding organization wants the plan broken out into phases or option periods, a worksheet must be completed for each phase or option period of the project.

RESEARCH ADMINISTRATOR 

Works with the Principal Investigator(s) to create a summary budget and small business documentation as described above, so that the Supplier Diversity Program Manager can then make the case for the specific types of goods and services that can be sourced from small business vendors. 

Forwards the budget and small business information to the Supplier Diversity Program Manager at least two weeks in advance of the date the plan is due to the Government and Business Contracts (GBC) Office.

SUPPLY CHAIN MANAGEMENT

Coordinates all aspects of the Small Business Plan process. Works directly with Principal Investigator, Research Administrator, and the Contracting Officer. Prepares and emails the following to the GBC for submission to the Federal Agency or funding organization: 

1. Principal Investigator Agreement Letter
2. Master Plan Notice 
3. Addendum A
4. Addendum B

These forms are required for the completion of the federally required documentation needed for the Small Business Subcontracting Plan. 

Small Business Subcontracting Plan Worksheet – Must be completed by Principal Investigator and Research Administrator so that Supplier Diversity Program Manager can complete the Small Business Subcontracting Plan documentation listed below.

Principal Investigator Agreement Letter – Assurance that Principal Investigator signs off on responsibility for making progress toward the small business utilization goals as set forth in the plan. Both the Supplier Diversity Program Manager and the Principal Investigator must sign this letter.

Addenda A & B – One Period – Excel worksheets which provide supporting documentation for specific percentage and dollars proposed for purchase of materials and supplies, equipment over $5,000, and travel from small business suppliers.

Addenda A & B - Multiphase – These worksheets are used when the proposal is for a multiphase or year project which requires a breakout of goals for each phase or year of the project.

Master Plan Notice – Official document sent by Supply Chain Management to the awarding agency or institution outlining UCSF's compliance with federal requirements.