Small Business Liaison Officer (SBLO) 101 and 102 Training

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Small Business Liaison Officer (SBLO) 101 and
102 Training

• DoD Western Regional Council for Small Business
  Education and Advocacy
• Raul Alvarado
• SBLO The Boeing Company

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SBLO 101 SBLO 102

• AGENDA
• Common Acronyms
• Why?
• Categories of Small Businesses
• Reporting Requirements
• Small Business Subcontracting Plans

• AGENDA
• Small Business Subcontracting Plans
• Small Business Compliance Reviews
• DLA 640
• SBA Preparation Checklist
• Management Commitment
• Training

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Common Acronyms

• NAICS
• SIC
• SB
• LB
• SDB
• WOSB
• HUBZONE
• VOSB
• SDVOSB
• FAR
• DFAR
• SBA
• ID/IQ

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WHY SMALL BUSINESS

• Amendment to SB Act (PL 95-507) - Passed in 1978
  
• Required Federal agencies to establish small
  business goals and provide an explanation to
  Congress when goals were not met.
• Established a OSDBU Office at each contracting
  agency
• Redefined minority firms as Socially and
  Economically Disadvantaged Small Business
  Concerns
• Established subcontracting plan for large
  businesses
• Reserved all awards under 25,000 for small
  business

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WORLD OF SMALL BUSINESS
SMALL BUSINESS
SMALL DISADVANTAGED BUSINESS (SDB)
VETERAN OWNED
WOMAN OWNED
HUBZone
8(a) SMALL BUSINESS
SERVICE DISABLED VETERAN OWNED BUSINESS
Javits-Wagner ODay (JWOD) AbilityOne
Historically Black Colleges Universities and
Minority Institutions (HBCU/MI)
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SMALL DISADVANTAGED (SDB)
DEFINITION - A SDB is small business firm that is
51 owned, operated and managed on a daily basis
by individuals who are socially and economically
disadvantaged.

• Socially Disadvantaged
• Presumed to be socially, racially, ethnically, or
  culturally disadvantaged or subjected to racial
  or ethnic prejudice or cultural bias
• African Americans
• Hispanic Americans
• Native Americans
• Asian Pacific Americans
• Subcontinent Asian Americans
• Other minorities as defined by the SBA
• 13 CFR 124.1002
• Economically disadvantaged
• Individuals denied access to capital and credit
  opportunities because of their identification as
  a member of a specific group
• Personal Net worth must be less than 750,000
  excepting
• Ownership by the principal(s) in the firm
• Equity in the primary personal residence

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SMALL DISADVANTAGED BUSINESS

• To represent itself as a SDB for Federal
  contracting, a firm must have
• Submitted application to the SBA
• Received certification from the SBA that it is a
  SDB
• For reporting purposes, a firm may not
  self-certify as a SDB -- if the SDB firm is NOT
  in the SBAs database (http//dsbs.sba.gov/dsbs/ds
  p_dsbs.cfm), then the firm is not counted as SDB.

FAR deviation
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SBAs 8(a) BUSINESS DEVELOPMENT PROGRAM

• Two-stage program
• Developmental stage
• First 4 years
• Emphasis on sole source contracts
• Strengthen financial managerial skills
• Improve access to markets
• Transitional stage
• Last 5 years
• Emphasis on competition
• Overcome remaining elements of economic
  disadvantage
• Prepare to graduate program

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WHO IS ELIGIBLE FOR THE 8(a) PROGRAM?

• Individuals who have been certified by the SBA as
  socially disadvantaged (refer to the previous SDB
  statement) and,
• Economically disadvantaged
• Personal business finances examined
• Access to capital/credit
• Entry level - less than 250,000 in personal net
  worth
• Rises as they progress in program

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WOMAN OWNED BUSINESS (WOSB)
DEFINITION - A WOSB is small business firm that
is 51 owned, operated and managed on a daily
basis by individuals who are women.

• Congress has mandated that DoD award 5 of
  contract dollars to WOSB.
• The Small Business Reauthorization Act of 2000
  (P.L. 106-554) allows WOSB set-asides
  (permissive, but not mandatory).
• Implementing regulatory guidance is currently
  being examined by the SBA.

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Historically Under-Utilized Business Zones
(HUBZone)

• Four Requirements to be a qualified HUBZone
• Must be a registered small business
• Concern must be owned and controlled only by US
  citizens 51 owned and controlled by US citizens
• The principal office of the concern must be
  located in a HUBZone and
• At least 35 of the concerns employees must
  reside in a HUBZone

The HUBZone Empowerment Contracting Program is a
community-based economic development program
designed to stimulate Job creation and Capital
investment -- in distressed areas
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VETERAN OWNED SMALL BUSINESS (VOSB)
DEFINITION - A VOSB is small business firm that
is 51 owned, operated and managed on a daily
basis by one or more veterans. In the case of
publicly owned businesses, at least 51 of the
stock must be owned by veterans.

• Veteran - A person who served in the active
  military, naval, or air service, and was
  discharged or released from service under
  conditions other than dishonorable.

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SERVICE DISABLED VETERAN OWNED SMALL BUSINESS
(SDVOSB)
DEFINITION - A SDVOSB is small business firm that
is 51 owned, operated and managed on a daily
basis by one or more service disabled veterans.
In the case of publicly owned businesses, at
least 51 of the stock must be owned by service
disabled veterans.

• Service Disabled Veteran - A veteran with a
  disability that is service connected as defined
  in Title 38 U.S.C. Section 101(16).

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HBCU/MIs

• Historically Black Colleges and Universities
  (HBCUs)Term used to identify accredited
  institutions of higher education established
  prior to 1964 with a principal mission of
  educating African-Americans.
• Minority Institutions (MIs)Term used to
  identify institutions, in addition to HBCU,
  having significant minority enrollments.
  Designated minority groups include
  African-Americans, Asian-Americans, Alaskan
  Natives, Hispanic/Latino-Americans, Native
  Americans, and Pacific Islander-Americans.

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NATIVE AMERICAN FIRM
DEFINITION An Indian-owned enterprise is
commercial industrial or business activity
established for profit with at least 51 Indian
ownership

• Ownership can be
• Individual where the majority owner(s) are of
  Native American descent
• Tribal - any Native American tribe, band, pueblo,
  or community, including native villages and
  native groups as defined in the Alaska Native
  Claims Settlement.
• Native American firms are not a SB category in
  the standard set of categories to these firms
• Native American includes American Indians,
  Eskimos, Aleuts, and Native Hawaiians.
• Thus Alaska Native Corporations (ANC), Native
  Hawaiian Organizations (NHO), and Tribal
  Corporations (TC), are all considered Native
  American Firms
• There are nuances associated with Alaskan Native,
  Tribal-Owned and Hawaiian Native Organizations
  that affect
• Eligibility rules
• Procurement rules

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Reporting SBLO 101

• ISR (SF294) Report on Individual Contracts
• FAR 52.219-9 (d)(10)(iii)
• Semi-Annual
• To DCMA, SBA, Contracting Officer
• SSR (SF295) Report on Agency Contracts
• FAR 52.219-9 (d)(10)(iii)
• Was Semi-Annual New UPDATED in Federal
  Register
• To DCMA, SBA, Washington, DC
• October 1, 2008 All Agencies on e-SRS

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Reporting SBLO 101

• Opt312 or equivalent New UPDATED by FAR
  Deviation
• Yearly with SSR (SF295)
• With Final ISR (SF294)
• Other
• As requested by Customer or Agency
• Semi-Annual Mentor-Protégé
• FAR 52.219-9(d)(10)(ii)

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CCR
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CCR
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How Many DUNS Do You Have?
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www.esrs.gov
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New Acronyms

• DRT Draft
• PEN Pending
• REJ Rejected
• ISR Individual Subcontract Report (FKA
  SF294)
• SSR Summary Subcontractor Report (FKA SF295)

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Plans SBLO 101

• Small Business Subcontracting Plans
• Types
• Comprehensive
• Commercial
• Master
• Individual

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Plans SBLO 101

• Comprehensive
• Test Program through 2014
• Negotiated annually
• Commercial
• Products sold to general public or industry at
  established catalog or market prices
• Contractors fiscal year

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Plans SBLO 101

• Master Plan
• Contains all required elements of an individual
  plan except goals
• Must be approved by
• Corporate Administrative Contracting Officer
  (CACO)
• Company Authorized Signature
• Covers a period of 1 to 3 years
• Individual Subcontracting Plan
• In conjunction with a Master Plan
• Specific to a contract covers entire POP
• Has goals based on Offerors planned subk effort
• Prorated allocation of indirect cost allowed (if
  applicable)

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SBLO 102
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• Why do we have these plans?
• What is a subcontracting plan?
• What are the required elements of a plan?
• Developing the Subcontracting Plan the Process,
  tips

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Why do we have these plans?

• It is the policy of the United States that SB,
  SDB, WOSB, VOSB, SDVOSB, HUBZONE concerns have
  the maximum practicable opportunity to
  participate in the performance of contracts
  awarded by any federal agency. Other-than-small
  business (OTSB) contractors are legally obligated
  to carry out this policy when awarding
  subcontracts to the fullest extent consistent
  with the efficient performance of their
  contracts. SBA Handbook for Small Business
  Liaison Officers
• FAR 19.702 and 19.702(1)
• Any solicitation over 650k requires a clause for
  subcontracting plans.
• If a negotiated award value (including options)
  is anticipated to be over 550k, any large
  business being considered for award, is required
  to submit a subcontracting plan as part of their
  proposal.
• 1 million for construction
• The Small Business Act (added by P.L. 95-507)
• Implementation is in FAR 19.700
• Clause is in FAR 52.219-9
• Additional implementation and clauses in FAR Sups

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Exceptions to this requirement for plans?

• FAR 19.702(2)(b)
• Small Businesses
• Contracts being performed entirely outside of the
  U.S. (including U.S. possessions meaning its
  states or territories. Washington, DC and
  Puerto Rico are INCLUDED)
• Modifications to contracts which do not contain
  clause 52.219-8

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What is a subcontracting plan?

• A subcontracting plan is a document setting
  forth how a contractor will provide SB, SDB,
  WOSB, VOSB, SDVOSB, and HUBZONE SB concerns with
  the maximum practicable opportunity to
  participate in the performance of a contract or
  subcontract. SBA Handbook for Small Business
  Liaison Officers
• A document submitted by a prime contractor which
  details what they will subcontract on large prime
  contracts. Specifically, what will be
  subcontracted to SB, SDB, WOSB, HUBZSB VOSB,
  SDVOSB.
• FAR 19.704

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Sample Subcontracting Plan

• SBA Handbook for Small Business Liaison Officers
• - Appendix C also has a Sample Subcontracting
  Plan

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Major elements of a subcontracting plan

• FAR 52-219-9 (d)(1) thru (11)
• Goals must be expressed as percentages of total
  planned subcontracting dollars
• A statement of total dollars planned to be
  subcontracted to
• SB SDB WOSB HUBZone
• VOSB SDVOSB

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Major elements of a subcontracting plan

• Description of the principal supplies and
  services to be subcontracted, and
• Identify the SB, SDB, WOSB, HUBZSB, VOSB,
  SDVOSBs that the products and services will be
  subcontracted to.
• A description of the method used to develop the
  subcontracting goals.
• A description of the method/process used to
  identify potential sources for solicitation
• Source lists, SBA Dynamic Small Business Database
  (FKA ProNet), Trade Associations, etc.
• A description of the efforts you will make to
  assure that SB, SDB, WOSB, HUBZSB, VOSB SDVOSB
  have an equitable opportunity to compete for
  subcontracts.

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Major elements of a subcontracting plan

• Assurance that you will
• Include the clause Utilization of Small Business
  Concerns in all subcontracts that offer
  subcontracting opportunities and require all
  subcontractors (except SB) who receive
  subcontracts in excess of 650k (1.5 M
  construction) to adopt a plan that is in
  compliance with the FAR.
• Cooperate in studies and surveys as required
• Submit periodic reports to allow the government
  to determine compliance with the plan
• Submit ISR (Individual at Prime Contract level)
  and SSR (Summary at Agency level) Subcontracting
  Reports
• Ensure its subcontractors submit ISR and SSR

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Small Business Compliance Reviews SBLO 102

• Prepare utilizing the DCMA Form 640
• Prepare utilizing the SBA Checklist
• May be joint audit by DCMA and SBA
• DCMA DoD Contracts
• SBA Non-DoD (NASA, DOE, EPA, etc.)
• Annually for Acceptable and Highly
  Successful Bi-Annually for Outstanding

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Small Business Compliance Reviews SBLO 102

• Outstanding
• Highly Successful
• Acceptable
• Marginal
• Unsatisfactory

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Small Business Compliance Reviews SBLO 102

• Common Issues
• Areas of weakness
• No documentation of assistance being provided to
  SB firms
• Size certifications not being updated
• Should be done annually on all, not just new
• Policy Procedures not updated to include new
  programs
• Back-up for dollars reported on ISR/SSR
• Training

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Small Business Compliance Reviews SBLO 102

• Management Commitment
• Policy Statement
• Issued by current senior management
• Disseminated throughout the company
• Indicate that Small Business subcontracting is a
  company policy and is the responsibility of each
  person in the company having procurement or
  requirement responsibilities
• Outlines authority for implementing SB program
• Identify distribution and assure policy provides
  objectives of National Small Business policy

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Small Business Compliance Reviews SBLO 102

• Management Commitment
• Policy Letter
• SBLO Appointment
• Policy Procedures
• Awareness of Small Business Programs

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Small Business Compliance Reviews SBLO 102

• Training
• Procurement
• Contracts
• Program Office
• Proposal Teams
• Outreach
• Conferences
• Referrals
• Assistance to Small Businesses

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Small Business Compliance Reviews SBLO 102

• EXAMPLES OF OUTREACH
• National Veterans Conference
• SB Local or National Association Meetings
• SBA Week April/May
• DoD Western Regional Council for SB Education
  Advocacy 4 times per year
• Navy Gold Coast August
• NMSDC October
• MEDWeek

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REPORTING
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http//www.esrs.gov/
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SPECIAL PROGRAMS
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Purpose of the Mentor-Protégé Program

• The Mentor-Protégé Program is designed to
  provide incentives for Prime Contractors to
  assist Small Disadvantaged and Woman-owned
  Businesses to enhance their business and
  technical capabilities and to increase their
  participation as subcontractors and suppliers.
• The program shall also foster the establishment
  of long-term, mutually beneficial business
  relationships between protégés and mentors.

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Types of Mentor-Protégé Agreement

• Cost Reimbursable
• Credit

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Agencies that have Mentor-Protégé Programs

• Army
• Navy
• Air Force
• DISA Defense Information Systems Agency
• DLA - Defense Logistics Agency
• DOD
• Energy
• EPA Environmental Protection Agency
• FAA
• Homeland Security
• NASA

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SBLO 101 and 102

• THANK YOU
• For your time and attention