At VCU we in central research administration have created a "template", as
it were, for creating a subcontracting plan.  We undertook it primarily
because we have some understanding of what's required and what's possible.
We found that leaving departments or PI's do try it resulted in mass
confusion.  Frankly, I see it as a necessary support research
administration gives.

Note that most university federal contracts are for activities conducted
almost entirely by the institution.  Typically, 75% or more of the direct
cost budget is for institutional personnel.  As to substantive performance,
we do not subaward.

For subcontracting plan purposes, however, "subcontracting" includes simple
procurement of goods and services.  We noted that most of our office
supplies are obtained from local distributors that qualify as small
businesses.  All our travel is through contracted travel agencies; they are
all small, and here in Richmond, VA, some are small-minority, and one is
small-minority-womens.

We have a further problem that state purchasing laws (we're a state U)
provide no room for Purchasing to select an other-than-lowest-bidder just
because Congress wanted to do a little social engineering.  However, vendor
selection has been delegated to the departmental level for purchases up to
$5K, so, with a little coaching, department can procure from a formerly
disadvantaged source.

We did have to develop the template in conjunction with Purchasing, and we
have a lot of boilerplate (fertilizer?) that justifies why we cannot comply
very well.  Reporting has to be worked out, too; central G&C accounting
does it.

Watch out for overzeallous contracting officers.  In some agencies or
offices they act as if meeting ever increasing small business quotas must
be part of their annual performance reviews!  You may even have to be
prepared to forego an award when the requisite subawarding "target" (I'm
thinking of one agency which aplies penalties if the target is not met!) is
greater than all of the non-personnel budget.

Chuck

At 12:37 PM 2/19/98 -0500, you wrote:
>Has anyone had to complete a subcontracting plan for a federal
>contract? If so, are your research administration offices
>responsible for its completion?  If not, which department at your
>organization?  I would appreciate any help or insights.  Thank-you in
>advance.
>
>
>Phyllis A. Thomas
>Contracting Officer
>University of Connecticut
>Research Foundation
>Telephone: 860-486-3337
>FAX:        "    " 5381
>
Herbert B. Chermside, CRA
Director, Sponsored Programs Administration
Virginia Comonwealth University
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