Government Contracts Class Deviation Addresses Small Business Subcontract Reporting
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Thursday, February 7, 2019

Class Deviation Addresses Small Business Subcontract Reporting

By Government Contracts Editorial Staff

The Department of Defense has issued Class Deviation 2019-O0005, Revision 1, which requires contracting officers to use, for orders or calls against basic ordering agreements or blanket purchase agreements, Alternate III of the clause at FAR 52.219-9, Small Business Subcontracting Plan, in lieu of the basic clause. COs must also use Alternate I of the clause at DFARS 252.219-7003, Small Business Subcontracting Plan (DoD Contracts), in lieu of the basic clause. In addition, when incorporating a subcontracting plan due to a modification to an order against a BOA or BPA, as specified in FAR 19.702(a)(3), COs must use FAR 52.219-9, Small Business Subcontracting Plan—Alternate IV (DEVIATION 2019-O0005), provided in Attachment 1 to the deviation, in lieu of Alternate IV of FAR 52.219-9, and Alternate I of DFARS 252.219-7003, in lieu of the basic clause.

Subcontracting Data Captured. Currently, the Electronic Subcontracting Reporting System does not support the submission of an Individual Subcontracting Report for orders placed against BOAs and BPAs. The deviated clauses instruct contractors to submit the Standard Form 294, Subcontracting Report for Individual Contracts, to the CO while eSRS is being modified to support the submission of ISRs, which will ensure DoD captures subcontracting data. This deviation, which rescinds and supersedes Class Deviation 2018-O0007 (¶70,245.80), went into effect on January 8, 2019, and will remain in effect until eSRS is modified to support ISRs for orders against BOAs and BPAs, or until otherwise rescinded. For the text of this class deviation, see ¶70,245.99.

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