Small Business Subcontracting Plans

This page is intended to provide guidance on the preparation and reporting required for such plans, and to set out the responsibilities of the various parties involved in their preparation and submission.

The University of Chicago is committed to providing enhanced opportunities for small business concerns to participate in the economic opportunities arising from the University’s business activities (see University Financial Policy 1205, Minority-owned, Women-owned, and Small Business Enterprises Procurement Policy). In addition, the University has accepted a number of federal government contracts with provisions requiring small business subcontracting plans, or similar requirements for documenting affirmative steps taken to utilize minority business enterprises.

A small business subcontracting plan is required on federal contracts that are expected to total an estimated cost of $650,000 or above for the entire period of performance. A small business subcontracting plan is also required of any subrecipient whose total dollar subcontract amount is expected to exceed total costs of $650,000 for the entire period of performance.

Any non-personnel (non-salaried) supplies or services required for performance of the contract are legitimate expenses to consider for a subcontracting plan. The principal products/services subject to the purposes of a small business subcontracting plan include direct costs such as: lab supplies, lab equipment, travel, printing, and livery services that may be sponsored by the contract. Any work included in your budget which will be formally subcontracted (i.e., a portion of the scope of work is contracted out to a subrecipient via a subcontract) to another entity, may also be included in the plan to use a small business.

A sample form for a small business subcontracting plan is usually incorporated as an attachment link to a federal contract solicitation (RFP).

A small business subcontracting plan is generally required to be submitted with the proposal, usually as part of the Business Proposal – it is subject to negotiation during the negotiation phase of a proposal. Federal agencies have established subcontracting goals and generally include them with each RFP; the goals are also often set out in the sample form for a subcontracting plan. At the time of the proposal, it is generally sufficient to prepare the subcontracting plan for the total cost of a multi-year proposal.

Responsibilities of University Parties

Departmental Administrator Responsibilities

  • Prepare small business subcontracting plans, consulting with PPS for suppliers as needed, and submit to URA for final review and signature
  • Prepare and submit required reports through eSRS: visit the site for guidelines and information
  • Maintain a list of vendors used to create the Small Business Subcontracting Plan, and update the list as needed
  • Monitor plan performance and make adjustments as necessary to achieve the plan goals
  • Provide feedback to Purchasing and Payment Services concerning vendor performance
  • Cooperate in compliance reviews or audit situations

URA Responsibilities

  • Review and sign final plan submitted with proposal
  • Notify Procurement and Payment Services when a contract has been awarded that has a small business subcontracting plan.

Procurement and Payment Services Responsibilities

Procurement and Payment Services and the Business Diversity will:

  • Make every effort to consult and assist in the identification of small business suppliers for inclusion and use under the plan
  • Develop and maintain a list of University approved/recommended vendors to satisfy the small business subcontracting plan requirements - List of approved vendors (PDF).

Resources