Jan 8, 2009

Vanessa Payne

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Resolution #4: We will meet our subcontractor reporting deadlines – embrace the “e”, save a tree!

Paper is out – the electronic Subcontracting Reporting System (eSRS) is here! If you are a LARGE business with a small business subcontracting plan incorporated into any of your contracts, April 30^th and October 30^th are your times to shine in 2009.  You should file your Individual Subcontract Report (ISR, former SF 294) and Summary Subcontract Report (SSR, former SF 295) at www.esrs.gov.

With online filing – no more “the dog ate my homework” excuses are allowed!  Track your subcontract awards according to your approved subcontracting plan – which may include these common categories: Small Business, Small disadvantaged Business, Women-Owned Small Business, HubZone Small Business, Veteran-Owned Small Business, and Service-Disabled Veteran-Owned Small Business.  Other categories may include: Historically Black Colleges and Universities, Minority Institutions, and Alaska Native Corporations.

Some helpful tips:

• Reports are required when due, regardless of whether there has been any subcontracting activity since the inception of the contract or since the last reporting period.
• Registration data can pre-populate based on DUNS number and FPDS-NG data. The 2007 eSRS FAQ indicates that address data corrections can be performed by contractors in the Central Contractor Registration (CCR).  Our experience, and the ISR form, indicates that address information pulls from FPDS-NG and therefore must be corrected by your Procurement Contracting Officer (PCO).
• ISRs are cumulative for the life of the contract, so they must be completed in chronological order.
• If you have multiple contracts under a single DUNS number, one SSR summarizes all data for the fiscal year.

If you have any questions about these reports or general GSA contract compliance, please contact Vanessa Payne at 301.231.6200, vpayne@aronsoncompany.com, or register to post any comments or questions you have to share on the topics.  Come back tomorrow for Resolution #5!