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Return to Article: Pilot program to gather subcontracting data moves forward

• 33383
  

  Regarding Mr. Tower's comment, the Federal Acquisition Regulations (FAR 44.101) define "subcontract". A subcontract includes purchase orders, changes and modifications to purchase orders. Generally speaking if money (or something of value) is exchanged for products or services, it constitutes a subcontract. Under an MSA, BPA or other "IDIQ-like" agreement, only the actual orders placed under the agreement(purchase order, task order, etc.) would have to be reported.

  Debra Blagg Posted September 19, 2007 1:02 PM
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  Since the intent must be to substantiate either fair-share or fair-value analysis with the collected information, use of current best practice processes needs to be recognized. For commercial companies with few Federal contracts, purchasing/subcontract decisions are made using our market-tested, six sigmaed, supply chain management proceedures. For my data to be meaningful regarding source selection, and price negotiation, my input needs to allow for a "Used in-place commercial process" HOW categoty (without having a government audited purchasing system).

  Phil Tower Posted September 19, 2007 12:02 PM
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  As there is now with the small business subcontracting reporting requirement, there is a need for a definition of 'subcontractor.' Many of my suppliers and vendors (for both services and materials)are considered (sometimes) to be subcontractors. Is a purchase order a subcontract? How about a long term (IDIQ-like) 'agreement' with key suppliers? WHICH 'subcontracts' will we be required to report?

  Phil Tower Posted September 19, 2007 11:33 AM
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  Regarding Mike's comment, not all contracts contain FAR 52.246-11. In addtion, FAR 52.246-11 is for "Higher-Level Contract Quality Requirement" (Feb 1999).

  Its requirement is:

  "The Contractor shall comply with the higher-level quality standard selected below. [If more than one standard is listed, the offeror shall indicate its selection by checking the appropriate block.]

  Title Number Date Tailoring [Contracting Officer insert the title, number (if any), date, and tailoring (if any) of the higher-level quality standards.]

  (End of Clause)

  Veronica Posted September 19, 2007 10:05 AM
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  This activity is long overdue. Prime contractors have not been forthcoming in their true subcontracting activities. Since so many of our tax dollars are expended with subcontractors, it is critical that this information be transparent.

  It will also provide information on subcontracting with the various categories of small businesses.

  I applaud those who are behind these regulations, because the lobbying against this by large primes must have been intense.

  Aleta Wilson Posted September 19, 2007 9:53 AM
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  If, in 2009, the requirement is to report on all subcontracts more the $25,000, regardless of the value of the prime contract, small businesses, such as distributors, will have a heavy reporting burden placed on them that will only increase overhead costs. There needs to be some thought given to exempting certain kinds of contracts for which such reporting will yield little useful information.

  Don Michels Posted September 14, 2007 11:10 AM
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  "...Many contractors do not regularly collect data about their subcontractors..." this is an inaccurate statement. All contracts containing FAR 52.246-11 is mandated to control subs and that is done with data about the subcontractor. Even without the clause a business not collecting data on subs would not be in keeping with best business practices. The data is there.

  mike Posted September 14, 2007 9:28 AM