Small Business Subcontracting Plan

When the University is awarded more than $700,000 in funding, it is required to submit a Small Business Subcontracting Plan. The following situations may lead to 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 $700,000 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 University is the prime contractor, as in item 1 above, 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.

The Federal Acquisition Regulations require one of the following actions during the project duration:

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 proceed with one of the following actions:

  1. Explain in writing the reason 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. See the Federal Requirements page to learn more about these reports.
  2. 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. 

For information about roles and responsibilities for creating a plan, see Small Business Subcontracting Plan Roles and Responsibilities.