Electronic Subcontracting Reporting System e SRS February 1

Electronic Subcontracting Reporting System (e. SRS) February 1, 2006

Electronic Subcontracting Reporting System (e. SRS) • The e. SRS is an electronic, web-based system for subcontract reporting that will replace the SF-294 & SF-295 paper forms. • When Do. D comes on board in FY 2006, it will be a Government-wide system and the only automated system authorized for subcontract reporting. 2

Organizational Structure • Systems Steward – U. S. Small Business Administration (SBA) • Contractor – Symplicity Corporation, Inc. 8(a) firm based in Arlington, Virginia 3

System Features (cont. ) Critical Systemic Linkages – Central Contractor Registration (CCR) – Federal Procurement Data System (FPDS-NG) • Government-wide agency hierarchy – DUNS numbers for prime contractors and subcontractors 4

IAE Architecture 5

Electronic Subcontract Reporting System (e. SRS) • The e. SRS is a downstream FPDS/NG application – – On the Positive Side: If a contract contains a subcontracting plan and has been entered correctly in FPDS/NG, the e. SRS automatically receives a record of it; – The Downside: If a contract is not in in FPDS/NG or has not been entered correctly, the contractor won’t be able to enter his ISR (formerly the SF-294) report at all 6

System Features • Business Processes – Identifies contracts in FPDS-NG having subcontracting requirements – Automates completion and submission of SF-294 and SF-295 • Will include the Annual SDB Breakout Report (3 -digit NAICS subsector) – When fully operational, it will also automate the Optional Form 312 7

Goal Computation on the ISR • The system calculates the achievements by two methods: ü% of contract value ü% of subcontracting __________________ Note: the e. SRS will only calculate the percentage on the achievement side, not the goal columns. This is by intent, because we want the contractor to copy the goals from the subcontracting plan exactly as they appear in the plan. 8

System Features (cont. ) • Provides breakout of subcontracting data down to the buying activity level. • Generates standard and ad hoc reports – – Analysis of Subcontracting Plan Goal Attainment Five-Year Trend Table SBA Goaling Report for Congress & the President Several other standard reports • Generates automatic reminder notices and delinquent notices. 9

Critical Milestones • Beta Testing and Acceptance – September 2005 • Initial Operating Capability (IOC) – October 28, 2005 • Full Operating Capability (FOC) – Target: 8 weeks after IOC 10

What Should Contractors Enter? (continued) • Civilian agency contractors must use the e. SRS for their Summary Subcontract Reports (SSRs) for the period ended September 30, 2004; and they must use the e. SRS for both their Individual Contract Reports (ISRs) and their Summary Subcontract Reports (SSRs) for the period ended September 30, 2005 11

Do Contractors Have an Extension for Filing? • OFPP memo dated Nov. 3, 2005, authorizes agencies to grant their contractors a 60 -day extension for filing the 9 -30 -05 reports (60 days from IOC) – Oct. 28 th + 60 days + 3 Holidays = December 31 st 12

What will FOC give us that IOC doesn’t? • FOC will provide an application interface so that contractors with electronic systems of their own can simply upload their data into the e. SRS (as opposed to keypunching it into the e. SRS one report at a time) 13

Is the FAR being changed? • SBA finalized a FAR case that includes changes to subpart 19. 7 and the related clauses, especially 52. 219 -9 • In the meantime, SBA’s Office of General Counsel has ruled that the e. SRS is the electronic equivalent of the SF-294 & SF-295 14

FAR Case • Revises subpart 19. 7 and clauses at 52. 219 -9 & 52. 219 -25 to replace all references to SF-294, SF 295, and Optional Form 312 with e. SRS. • Revises the flow-down provision at 19. 704(a)(9) and 52. 219 -9(d)(9) to require the prime contractor to flow the prime contract number down to the subcontractors at lower tiers – prime contract number now becomes a mandatory field in the e. SRS, even for subcontractors, in order to facilitate lower-tier reporting. 15

FAR Case (cont. ) • Moves “General Instructions” from the paper forms to the clause at 52. 219 -9. • Requires contractors to print a hard copy of the Summary Report(s) and have them signed by the CEO. • Contractor will be required to keep hard copy with CEO’s signature on file for 4 years. • SF-294, SF-295, & Optional Form 312 will all be deleted from Part 53 – i. e. , abolished! 16

FAR Case • The Small Business Committee of the FAR Council will review and discuss the specific provisions in the proposal • The regulation will be issued as a Proposed Rule or Interim Final Rule – 60 -day public comment period • Final Rule will reflect changes resulting from public comments, as appropriate 17

LOWER TIER REPORTING Individual Subcontracting Reports (ISR) Former SF 294 • • • Prime Contract Number Higher Tier DUNS Product and Service Lines NAICS Email Address of the Govt Official to Review the Report • No Inclusion of Lower Tier Dollars 18

LOWER TIER REPORTING Government contracts with Company X Contract Number DE-AC 01 -05 EE 12345 Company X will include on their Individual Subcontracting Report: Their Duns is 001339457 Prime Contract Number- DE-AC 01 -05 EE 12345 Company X subcontracts with Company Y Contract Number XX-05 TP 00023 Company Y will include on their Individual Subcontracting Report: Company X’s DUNS-001339457 Prime Contract Number- DE-AC 01 -05 EE 12345 Their DUNS-113456896 Contract Number with Company X-XX-05 TP 00023 19

LOWER TIER REPORTING (cont. ) Company Y subcontracts with Company Z Contract Number YY-05 DD 99963 Company Z will include on their Individual Subcontracting Report: Company Y’s DUNS-113456896 Prime Contract Number- DE-AC 01 -05 EE 12345 Their DUNS-132568700 Contract Number with Company Y- YY-05 DD 99963 20

Summary Subcontracting Reports (SSR) Former SF 295 • Product and Service Lines • NAICS • Email Address of the Govt Official to Review the Report • No Inclusion of Lower Tier Dollars 21

REVIEW OF REPORTS Government will review: – Prime Individual Subcontracting Report – All Summary Subcontracting Reports Higher-Tier Subcontractors will review: – Lower-Tier Individual Subcontracting Reports 22

Accounting Methods • “Commitment Basis”- means that you capture the transaction when you execute the subcontract award document. • “Payment Basis”- means that you capture it when you pay the invoice. If you use some other method, or hybrid of the two, the system allows you to select “other. ” Once you select the method, it can not change for the life of the contract. 23

Acceptance of Reports • "Acceptance" does not mean approval, per se, but it does mean that the Government has reviewed the report and that it appears to be complete. Since an on-site compliance review later on could identify flaws in the preparation of the report, the Government always has the right to reject a report that has previously been accepted. 24

How will the e. SRS Help Desk work? • The Help Desk will handle all technical questions regarding the use of the e. SRS – E-mail address is Help@esrs. gov • Questions regarding subcontracting policy will be referred to SBA • Other problems/issues will be forwarded to the Agency Coordinator of the agency that awarded the contract 25

TROUBLESHOOTING CCR ISSUESCCR Assistance Center 888 -227 -2423 FPDS-NG ISSUES Call the Contracting Officer e. SRS ISSUES Contact the e. SRS Helpdesk 26

Contacts for Policy Questions • The CMR listing at http: //www. sba. gov/GC/cmr. html provides the names, addresses, phone numbers, fax numbers, and email addresses of SBA’s CMRs-roughly 36 people. Contractors using the e. SRS who have policy questions should call their nearest CMR. 27