eSRS Presentation for Government Employees

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>> Teresa Lewis: Hello
everyone my name is Teresa Lewis. I'm the OSDBU director at the Department
of Health and Human Services. As part of our acquisition
training series we're providing training today
on eSRS reporting. I'm extremely excited to
have with us a subject matter expert from the Small
Business Administration. Angella Terry is the
subcontracting program manager for the entire
federal government and I'm extremely excited
to have her here. Angella, thank you for
coming to HHS and thank you for sharing your time and
doing this training with us. Thank you
so much. I'm really looking
forward to it. >> Angella Terry: Okay,
great. Thanks for having me. Today's subject is about eSRS. We are going to talk about the
roles and responsibility of ESRS as well as how to review
subcontracting reports, both summary reports
as well as individual subcontracting reports;
and I look forward to answering any questions at
the end of the training as well. Okay, so the presentation
I have in front of you is the subcontracting
reporting presentation. It is about post-award
responsibilities. We're going to go
through the government's responsibilities as well as the
contractor responsibility.

As you all know, ESRS is
the sub award reporting system for subpart 19 of
the FAR for small business subcontracting accomplishments. This is where you would go
to accept, reject, review, and communications of
the prime contractors and subcontractors of
summary subcontract and individual
reports. The government's
responsibilities are to register an eSRS, provide
roles to the subcontractor supporting staff, as well
as assist contractors in need of assistance, review
subcontracting reports, approve and reject those
subcontracting reports, monitor subcontracting
accomplishments, and communicate with
the contractor. We ask that you do all
of this in the eSRS subcontracting system and
I will be showing you that system so that you'll
understand how that is done.

In eSRS, we have
established roles. In order for you to view
the subcontracting reports you are responsible for
reviewing, it is very important that you
one, register at ESRS, and then be assigned
the right role. Agency coordinators
at your agency are responsible for attending
the CCB meetings with the integrated acquisition
environment, they're responsible for approving
registrations, as well as providing assistance for
the government personnel as well as
contractor. They are also responsible
for disseminating information throughout
your organization on subcontracting as
well as the eSRS system.

They do have
responsibility for reviewing, accepting,
and rejecting reports. We also have a role of a
point of contact which is just like an agency
coordinator but they're more of an alternate when
it comes to attending meetings. The contracting official
is more of a C.O. responsibility who has the
responsibility of actually reviewing the individual
subcontract report and the commercial
plan report. They may also have
the responsibility of reviewing the summary
individual report as well. And then you have the
designated government user who is just someone
who runs queries and wants to view information
within the report. What's important is if
you have the role and responsibility of
reviewing these reports you must be designated
with the right role and the right
office. If you are not, you
will not be able to see your
reports. So if someone has informed
you that you have the responsibility of
reviewing these reports, you've registered in eSRS,
you logged in and you see no reports in your queue,
it is because you are not registered for the correct
office and you need to contact your agency
coordinator and your point of contact
at that time.

I'm now going to go into
the eSRS system because I do want to show you,
there's two different portals for eSRS as you
see the screenshot, have you the contractor's portal
and the government portal. On eSRS you'll
have user guides. These user guides are
navigational guides of how to utilize
the system. They will tell you how
to accept and reject a report, what buttons to
push, what you can do once you push those
buttons. The training material
you see in eSRS is quick reference guides that
actually give you Subcontracting 101. So if you're new to
your organization, or if you need a refresher
about subcontracting responsibilities, then
the only thing you need to do is pullout this training
material and it will give you exact information
that you need to go on and do your job. That training material
is also at the bottom of every screen that
you're on in eSRS and then I'll show that
to you momentarily.

In addition to that if you
have a new contractor that is new to government
contracting, you can also point them to the training
material because we have two types, we have
training material for the government and we have
training material for the contractors, and we have
sample reports so they can see the type of reports
they will be responsible for reporting. As I mentioned to you
before, if you log into eSRS, this is the home
screen that you will see. If you do not have any
reports in this queue, it is because you — and you
know for certain you have contractors who have
submitted their reports, it is because you are
not registered to the right contracting
office.

And what you would need to
do is contact your agency coordinator and let them
know and I'm sure they will fix that
on there. What we will do now is go
into ESRS so that we can actually look
at HHS reports. Okay, just give me
one moment here. Here we go. I apologize
for that. So we'll go into an HHS,
excuse me, subcontracting report and
review the data. What I wanted this to be
is a hands-on project whereas you'll actually
get to see a report, you'll get to see the
data fields that need to be reviewed, you'll get
to see how we expect for to you communicate within
the report with your contractor. Prior to eSRS, we had a
paper based system whereas we would get these reports
and review them and pick up the telephone or send
an e-mail to someone, let them know we had sometime
of issue with the report, and then once we did that
we would wait on them to get back to us and
end up putting something in either contracting file
or, you know, we'll have some other type of
file where we've communicated with
the contractor.

That now we have eSRS, all
the communications that we do goes directly
into the report. When a contractor wants
to communicate with us, we advise the contractor
what they need to do is put their comments in the
remarks field and what the government person would
need to do is put their remarks in the reject or
approval field at all times. All right. Just give me
one moment. We will go to a
summary report. We're going to pull up
— all right, so we're looking at an
HHS contractor. This report is in pending
status, it is a commercial plan report. A commercial plan report
normally has an improving agency, that could be your
agency or it could be another agency. The approving agency is
based on the contractor who originally — excuse
me, the government agency who originally approved
the commercial plan, and once that is done, anyone
with the longest period of contract performance
will be the individual responsible for approving.

However, if you have
accepted that commercial plan report, you still
have the responsibility of reviewing that report, of
viewing HHS or your agency subcontracting
accomplishments, contacting that approving
agency, letting them know they either except the
report on your behalf or reject the report
on your behalf. In order for you to
communicate with that contracting officer, you
would need to look in the agency section of eSRS,
you would click on organization, and you
search for that particular organization and contact
the agency coordinator. That agency coordinator
will communicate with whomever in their
contracting office that has that
responsibility. And if your request is
to reject it, they will rejects it, if your
request is approve it, they will
approve it.

What I need for you to
understand, if you do not approve the report your
agency will not accept credit for it. Any report that is in
pending status, that agency does not get
credit for it in their annual subcontracting
accomplishments. Any report that is in
reject status, they will not get credit
for it as well. In addition, no
report should ever be in reject
status forever. Reject status is just
to communicate with the contractor that we have a
concern and that concern needs to be
addressed. Once that concern is
addressed we need to document that
within the report, and I'll show you
how to do that. So one of the things you
would definitely need when reviewing a report is to
have either the individual plan, subcontracting
plan, or the commercial subcontracting plan.

So as you're reviewing the
report you will be able to see if this contractor
is meeting their goals or not meeting
their goals. On the commercial plan
report itself it will not show you the goals,
it will only show the accomplishments, and that
is why you would need the subcontracting plan so you
will be able to identify if they're meeting
their goals or not. So the first thing we
want to do is make sure we have a commercial plan
with this particular contractor. Often times I receive
calls from agencies saying "Angella, this company is
submitting us a percent attributable to
their subcontracting accomplishments,
however we don't have a contracting
plan with them." So you need to be able
to verify by having the subcontracting plan
whether or not this particular vendor
is someone you have a commercial
plan with. If it is not you
definitely need to reject the report and advise
them they are not.

However as you begin to
review the DUNS number, the name of the vendor, if
you can verify that they have a commercial plan
with you, you would just go down the report, ensure
the date they submitted the report is in the
proper field, the reporting year is correct,
and then you want to make sure the description of
their major products and services is what is on
your commercial plan report.

In addition, to that, you
want to make sure that their small business,
large business, and social economic categories are within
the goals that was submitted. If they are not, as you
see this particular contractor has done no
subcontracting at all, and that is because
perhaps there is a reason. However, if they have not
given us a reason in the remarks field, we need
to reject their report, because what we would
want to know is why. In addition, they've given
HHS 35 percent of their subcontracting
accomplishments and they've
done none.

So this tells me that this
particular contractor needs to be educated
on how to file this particular
report. In the remarks field, we
do tell them, if you have entered a zero in the
small business section of this report or failed meet
the dollar or percentage goals in the commercial
subcontracting plan, use this section to explain
the reason for any short falls or your future
plan of action. For this particular
contractor, what they added was "We have bid and
lost task orders and have not been awarded any
task orders to date. We will continue to review
bids, submit proposals, and market
this vehicle." So what that tells us is
this particular contractor had a commercial plan on a
base contract that would have task orders
associated to it. Even if they have no
subcontracting, they are still responsible for
submitting a report as this contractor
has done. They have entered the
totals of zero because, again, they have not been
awarded any task orders, so they have no subcontracting
accomplishments. This can happen also if
a contractor was awarded a contract in September,
the reporting period is at the end of September,
so they haven't had the opportunity to do
subcontracting, so of course they still have
to file the report and the subcontracting
accomplishments will be zero.

It can also happen in
a five contract year in which two years of
the contract has been exhausted, however they
don't plan to do any subcontracting until
the third year. However, they are still
supposed to advise you in the remarks field, what
the course of action is, and why they have
zero dollars. If you do not have that,
when you go to review at the accept or reject
status of the report, which is at the top level,
you have this drop down menu, you simply click it
and you have the option of accepting
or rejecting. If a contractor has not
advised you why they have zero dollars, or why
they have not started to meet their goals, or if
you see they're having some type of short falls, you
need to address it immediately. Please keep in mind that
the commercial plan subcontracting report
is fiscal year based. So if they have not met
their goals then they're not going to meet them
for this particular subcontracting plan.

We have an issue. We need to address that
issue immediately. It is very good to
communicate with your contractor throughout the
course of the year to see if they're having any
short falls, having any struggles, because it's
our responsibility to assist them with finding
contractors if they need that assistance. If this was a contract
that actually had dollars and percentages, therefore
they're subcontracts — I'll go back to the reject
and approve status. If this was a contractor
who actually had dollar figures in their
contracts, the dollar figures
will show here. It will then be their
responsibility to tell us what percent attributable
is HHS' portion. In many cases,
another agency would be the approving
agency. In this case, HHS is
the improving agency, in some cases it
could be GSA. So what you would see is
the dollar figures for that in your queue when
you go to look at their report but you will not
have the accept or reject functionality here in
the right hand corner, and that is because you're
not the approving agency.

In this instance this is
when I advised you that you would have to come
over to the agency section, look up the
organization, and contact and an agency coordinator
in that office and advise them to either reject
the report or accept the report on
your behalf. One of the major problems
that we have with the commercial plan report is
contractors are somewhat confused and what they
would like to do is give the government a hundred
percent attributable for their
subcontracting awards. The government can never
be a hundred percent attributable on a
commercial plan because the reason why they
were allowed to use a commercial plan is because
they sell a commercial product and they do
business with other than the
government. So at no point in time
can the government have 99.9 percent or 100
percent of their subcontracting
accomplishments. Normally what I would do
is I review commercial plan reports since we have
such a problem with that. I would contact the agency
and reject the report on their behalf and
start communications with the contractor.

A lot of times contractors
just need support and training to understand
what really needs to be done on those
commercial plan reports. If you are reviewing a
commercial plan report and you see that they've
given you 90 percent or 99 percent, you need to
start communications with that contractor, one, to
ensure that they understand what's supposed to
be reported as well, to ensure they have reported
the correct dollars. Again this contract is
zero and why would they give HHS 35 percent, because
HHS has done nothing? So that tells me that this
contractor would need some type of
training. So when they do get
task orders, they will understand what
is required. In addition, I find it
very hard that they have no subcontracting
accomplishments. A commercial plan is a
plan that the company developed for their
organization prior to getting any contracts
with the government.

This company said we would
like to have or to give back to small businesses in
social economic categories of small businesses
so this is what we're going to do in our
subcontracting arena. It has nothing to do
with the government. Because they've already
outlined that on a plan, that means they
have already begun to execute
that plan. So that tells me that
this company does not understand that the
accomplishment that goes in this report is on the
company's commercial plan and not for the work
that they've done with the government.

In addition, that tells
me, based on their remarks that they were only
putting things in with the government. So I would have to reject
this report, advise the contractor that the
dollars that goes in small business, large business,
and social economic categories are based on
the company's overall success in subcontracting,
not just the work that they've done with
the government. That is very important
that we understand that. And when it comes to a
commercial plan, it is not just what has been done
with the government, it is the overall
accomplishments with the organization for
their commercial plan and at no time that should be
zero unless they've done no business
at all. So when you're reviewing
a commercial plan and you see zero there, reject
the report, advise or ask the contractor why is it
zero dollars on their commercial plan. Make sure they understand
that the dollars figures that go in this report is
not government specific.

The only thing that's
government specific would be the percent
attributable to the government. Again that's very,
very important. It is not just what
they've done with the government, it is what
they've done with the organization for the
products and service we approved on the
commercial plan. In addition, the percent
attributable would be HHS' percent attributable
for the subcontracting accomplishment, which in
this case would be zero because HHS has not
awarded them any contracts. So if they've done a
million dollars total in subcontracting on their
commercial plan, when they went to give HHS a percent
attributable, it would be zero and not
35 percent. Okay. In addition, what we would
do is just make sure they've completed — they've
certified their data. We also tell them that
the certification of the data is a testament
that they're submitting the report accurate and
it only includes dollars and percentage of their
contracts and not their lower-tier
subcontracts.

If they put "no," here,
instantly you need to reject the report
because if they don't want to certify that their data
is correct then there's no need for us
to review it. In this case, they
certified that their data was correct because
I'm sure they think that they're reporting
correctly even though we now understand that
they are not and they need to be educated in
how to report their subcontracting
accomplishments. In addition to that, we
need to ensure that they have stated that the CEO
or the highest authority of that organization has
approved this report.

That means that individual
knows they're reporting these dollars and that
individual is okay with that. If we do not have that
information, we need to reject the
report as well. Because what that is
saying is the CEO or the highest tier of the
organization is not in align with this
particular report, okay? We do ask they enter
an e-mail address but it's very important that
you know, that does not mean the HHS individual will
not see the report if they do not put your
e-mail address in. As you know we have
turnover, we have people will have different
positions assigned to them, so at no point in
time do we rely on this e-mail address in order
for you to have visibility to the report. As long as you have
registered for the right contracting office, you
will have this ability of the report once
you log into eSRS. Now that we've reviewed
the report, I would go back up to the
accept and reject.

For this particular report
I would reject it and whenever you reject a
report, you must enter a reason for
your rejection. Whenever you see a
red asterisk in ESRS it is because it is
a required field. For this report I've rejected
it for several reasons. The first rejection reason
is, I rejected to start communications with the
contractor on why have they not done any
subcontracting on their organization's
commercial plan.

Two, I would advise them,
are they aware that the dollars that go in this
report is the overall subcontracting
accomplishment and not just work with
the government. Three, I would advise them
that HHS is not 35 percent of their subcontracting
dollars, at this time HHS would be zero because
we have not attributed anything that is
subcontracting because we have not awarded them any
contract at this time. I would then ask if they
need any additional training on how to report
their subcontracting actions and I would ask
them to contact me. I would also ask them to
enter anything that they would like to reply in the
remarks field so it will be documented
in the report. Once you communicate
with them by telephone or e-mail, I would then come
back into the report and add that information in
the reject notice as well. The reject notice stays
in the report indefinite under the notes
tab, as you see it. So if you're no longer
responsible for this particular contractor and
someone else is, when they come in they're able to
review the history of the report instead of having
to go to some contract file and look that
information up.

Now, if this was a perfect
report and everything was reported correctly, I would
just accept the report. When you accept a
report, you do not have to add any
information. You can, you know, let's
say you're accepting report understanding that,
you know, this contractor hasn't done any
subcontracting as of yet because they won't be
doing any subcontracting until three years into
their five year report. you would still, if I were
you, you would still enter a note to say "I have
communicated with the contractor based on
no subcontracting accomplishments, the
contractor has informed me that their subcontracting
efforts will not go into effect until the third
year of the contract," so that SBA and others will
know that you just didn't overlook the fact
that this contractor has done no
subcontracting at all.

Okay. That is the summary of the
commercial plan report. I now want to show you
an individual report. We always do — we have
commercial plan reports but we also have
individual reports for summary reports
for the SSR. Let's just
take a look. When we do individual
reports they are contract specific for
the ISR, the Individual
Subcontracting Report. However for the summary
report, they are not. They are general. They include what the
contractor has done on specific contracts as well
as what the contractor has done on contracts that are not
specific with the agency. And it's very important
that you understand that. So when you look at
a summary report for an individual contract, it
is because the contractor once met the threshold
where they were required to do an individual
subcontracting report and they're now reporting
on all of their subcontracting efforts that
they have with your agency. That is for contracts that
did not meet the threshold as well as for contracts
that did meet the threshold.

We're going to look at another
agency report for that. So the first thing
you would do is look at individual to make sure
it is an individual and that that company has an
individual subcontracting plan with your
organization. If they do not have an
individual subcontracting plan with your
organization, immediately reject the report, advise
them that you do not have — that their organization
does not have a contract with your organization,
and they have reported their subcontracting
accomplishments to the incorrect agency. Okay? As you look down the DUNS
number, you ensure that is the company that you
have the contract with, you ensure that the
reporting period is correct, you ensure that the NACES
[spelled phonetically] is the NACES that have
you the preponderance of business with particular
organization, and then you just look at their
accomplishments. When it comes to the
summary contract for ISR, you are really not looking
to see if they met their goals because their goals are
not on this summary report.

What you're looking at is
to see the subcontracting accomplishments for this
particular company overall for your agency. What can you see is this
company does 34 percent this fiscal year in
small business for HHS. And 34 — that 34.4
percent was all with SDB businesses. That could be 8(a) firms,
self-certified SDB firms. In addition, to that, they
also need to make sure they input who do you need
to talk to if you had a problem with
this report? We normally don't have
problems with the individual subcontracting
summary report because with the organizations
are doing is just lumping up all of their
subcontracting that they have with the
agency and entering it.

But if you ever needed
to communicate with them about their subcontracting
accomplishments, this is the section you would
go because it tells you who administers the
subcontracting program for the
organization. And it gives you their
phone number immediately. Again, we ask them to
certify to this data. If they're not willing to
certify to the data then we say reject
the report. We also ask the chief
executive for the officer or the highest
tier in this organization to review this report as
well so they can also know the dollars that they are
reporting on the report.

The same goes with the
e-mail address here as well. Again, just because we ask
that they put an e-mail address they can put
someone in their organization, they can put
someone at HHS, the only thing that this is letting them
know is someone has reported. If you have a
responsibility then you know, that can you go
to your account, log on, and just view
the report. If you have gotten an
e-mail from them and you log on to your account
and you don't see it, keep in mind it is because have
you been registered to the incorrect office and you
need to contact your agency coordinator, so
your agency coordinator or point of contact can
sort out the right agency office that you need
to be reporting on. Okay. Again, once you have
reviewed the report and you're ready to accept or
reject it, the same action occurs, you go
to reject.

If you reject, you must
put a reason for your rejection, and
just hit submit. If you accept, then you
do not necessarily have to put a reason why you
accept, but the only thing you would need
to do is submit. Once you've done any of
those, whether it's reject or accept, your
information will show right here indefinite
in the report. Okay, we're now going
to go to an individual subcontract report so
that we can review that. Again individual
subcontract reports better known as the ISR, are
contract specific. They belong to a
specific contract, they are cumulative for
inception of the contract, and they are due
twice a year.

They are due at six
month interview and the annual
interview — interval. I'm going to look at this
particular contractor. Their report is
in pending status. It is an
individual report. You definitely need the
individual subcontracting plan when reviewing the
individual subcontract report. You cannot review this
report without the subcontracting plan
because what you're looking for with this
plan is to ensure that they met their
subcontracting goals.

The only way that you know,
that they've met their subcontracting goals is by
having the subcontracting plan. If they do not have
the plan then you just cannot review
the report. The first thing you need
to make sure is the DUNS number of that
organization is the same DUNS number
on that plan. You need to make sure that
the vendor information is correct, you need to
make sure they enter some contact
information. You need to make sure
that the reporting year is accurate because when
they're reporting they can report for the current
fiscal year and five years prior, so you want to make
sure they are reporting on the proper
fiscal year.

Now they cannot do
more than one report in the same
time frame. Okay. The agency that they're
submitting their report too is automatically fed
from FPDS-NG which is the federal procurement data system,
they do not select that. Whatever agency
awarded the contract is automatically prepopulated
in this particular area of the report. Again, they must put in
their major products and services, that's on
that subcontracting report, and you want to make sure
this matches what's on that report to ensure that their
reporting on the proper data. Now when you look at this
report, okay, we're not at a summary report —
okay, I need to go back.

My apologies, this
is a summary report, and we want to be at an
individual subcontract report. All right. Let's go. As you can see you have
plenty of outstanding reports for various fiscal
years but we just want to look at 2014 report
and while I'm here, let me just explain these
filters to you. Anytime that you're in eSRS
you have specific filters. If you want to look
at a specific status of a report, have you draft
reports which are reports that were begun, no one
finished, which is on the contractor side but if
you're not a super user of the system you will
never see a draft report. A pending report is a
report that the contractor has submitted to the
government and is awaiting for the government
to review it. A revised report is a
report that was submitted to the government, the
government reviewed it, they rejected the report,
the contractor went back in, fixed the report
and — has revised it, and is now waiting for the
government to review it. And an accepted report was
a report that a contactor submitted, the government
reviewed it, didn't see errors or known issues or
questions with the report, so they have acknowledged
receipt of receiving the report.

Again, a rejected report
is a report that was submitted to
the government. We did see some
issues with it. We had known errors so
we rejected the report to start communications
with the contractor. A reopened report is a report
we had previously accepted. We then either got
some information, maybe a contractor
called us and said "Hey, I made an error
on that report. I need to
fix it." In order for them to fix
it we would have to reopen it. Or maybe we're doing some
type of internal review, and we look at it, and see
something that's questionable so we're going to
contact that contractor by reopening their report
and letting them know we have concerns. For the sake of
our presentation, we are looking at
pending reports. There's different
types of reports: there's a regular report
and there's a final report. A regular report is
the report that's due while the
contract is open. If it's a five year
report, then you expect to see two reports each
year for five years.

However, when that
contract has ended, they need to do
a final report. The final report means
there's no more reports you will be receiving
coming in for that particular
contractor. If you want to see the
prime reports or the sub reports, prime reports
are reports that have been supplied by your prime
contractor, sub reports would be the
subcontractors of your prime
report. As you are aware, we
have a full down clause in their prime report
that states the prime contractor or the
higher-tier subcontractor is responsible for
reviewing the data on a subcontract report of their
lower-tiered subcontractors. Very important that you
remind them of that. And again, can you then
sort for particular contracting year. These fields here with the
arrows are ascending and depending as well.

You can click them and
then they will also provide you with sorting
the data for you. We're going to look at
this particular individual subcontract
report. So as I said first,
it's pending. We want to make sure that
DUNS number is someone that we have an individual
subcontract plan with. The verified data is
very important, too. So in order for them to
report on their individual subcontract report, the
system is fed data from the Federal Procurement Data
System, Next Generation. In the beginning when we
started eSRS, we had many problems because a
contracting officer is responsible for putting
this data available in FPDS-NG and then clicking a
button stating the plan is due. When the contracting
officer does that, it flows data over the
eSRS which allows the contractor then to view
their contract to report. As I stated before,
the ISR are specific to a contract and this
is the contract number.

So when a contracting
officer is going in to review reports, they
should have a listing of each contract that a
report is due on, and all they have to do is go
down the report looking at those contract numbers
to ensure the contractor has reported. Again, it is very important
that they have their subcontracting plan where
they will not be able to accurately
review this report. If the verified data,
meaning — the question to them is, is the data correct
that comes from FPDS-NG. The first 14 fields is
data that is prepopulated from FPDS-NG, from
the DUNS numbers, to the vendors name, the
vendor's address, the date that the contract was signed,
the agency that awarded the contract, the agency's
office ID, the agency name, the office ID,
the funding agency, the funding amount, the
product and service code, all of this information
comes — oh, the first 19 fields — comes
over from FPDS-NG.

So if the contractor says
"Hey, this information is not correct," then we just
don't even need to review the report, we need to
stop, we need to reject it, and ask why did you
report or what information is incorrect. Hopefully what they've
done if the information is incorrect they noted
that in the remarks field. We just go to the remarks field
and that's where we tell them to communicate with
us and we can identify what problems
they had. For this particular report
they said the data was accurate, so because the
data is accurate all we need to do is to scroll
down and look at the report. I would say you need to
verify this data as well as the contracting officer
to make sure data did actually flow over from
FPDS-NG accurately.

If you find that the data
is incorrect, then you still need to reject the
report, figure out why the data is not accurate, and
then ask the contractor to redo their reports once
you've gotten the data to be accurate. Now, number 20 asks
is their contract administered by
another organization. I don't believe HHS
has contracts that is administered by someone
else, but often times they are administered by DCMA
or some other agency. And what means is that
agency is responsible for ensuring the contractor
is incompliance with their subcontracting
dollars. And in that case, the
contractor would say "yes," here and they would
select that agency who administers their report
and both the agency who awarded the contract as
well as the agency who administered the contract
will have access for visibility of
that report.

Again, we ask them to put
the contact information of the individual who is
filing their report. We normally would ask and
in the training material it does ask this
individual to put their name, phone number,
and e-mail address. In this case the individual
just put their name. We want to make sure
the reporting period is correct and the
reporting year is correct, and we want to make sure
that the report is correct. This particular company
say it is a final report. That means their contract
has ended and this the absolute last report
they will be filing.

So if you know, that hey,
the contract hasn't ended they have two more years
on this particular contract, you need to
reject the report and let them know they have
selected the wrong type of report and they need to
go back in and correct that. They're saying they're
reporting this action as the prime
contractor. As you know,, they have
the option to report as a prime or a subcontractor,
so you want to make sure that this is definitely
the prime contractor that you have awarded
your contract to.

Now this is the meat and
potatoes of this report. Again, the individual
subcontracting report is to ensure that the
contractor you have awarded this particular
contract to is actually doing due diligence to
meet the goals on their subcontracting plan. The only way that you're
going to know that they're doing that is to ensure
when you're reviewing this report that you have
their subcontracting plan available when
reviewing. All the data we're now
going to talk about is verbatim from the
plan, except the actual
accomplishments. Everything else we're
asking whether or not they have included indirect
dollars or direct dollars in this report. If they're subcontracting
plan did not say they could include incorrect
dollars, in the ISR report, they're not
able to. So if you're reviewing
this and they say they did have indirect dollars and
you look at their plan and it says they cannot, then
you reject the report and ask them to redo their
report subtracting the indirect dollars, but in
this case it told us they do not have
indirect dollars.

In addition, what you want
to review is that the goals in the goal
column is correct. You want to make sure
that they mirror verbatim what's on the
subcontracting plan. So they were supposed
to do 651,000 in small business and 1.3 million
in large business, and their total subcontracting
was 1.9 million. You want to make sure
that is what we have agreed to on the subcontracting
plan, and the only thing you would need to do is take a
look at the plan and the data. In addition to that, you
want to make sure that their goals for their
social economic categories are correct. This is particular, but
it could be correct. They have the same
goal for SDB, WOSB, and HUBZone and they have the
same goal for Veteran and Disabled Veteran. Normally you would not
have the same goals. But for whatever reason, we
have elected for them to do so.

If that is accurate
information, fine, we continue on with
what we're doing. So the next thing we want
to do is to see are they on target to
hit those goals. For this particular
contractor they exceeded their goals already,
they've issued one point — one million in small
business contracts, they've issue 1.1 million
in large business contracts, so they've
actually exceeded our expectations on what
they were supposed to do for small
business. They have — they
exceeded their SDB goal, they exceeded WSOB goal,
they exceeded HUB — no, they didn't quite meet
their HUBZone goal, but we wouldn't beat
them up for that. We wouldn't beat them up
for that because they exceed indeed
other areas. They exceeded their
veteran goal. Now, they did not meet
their SDVOSB goal, however, I would like
to make sure that this company knows that
anything they put in their SDB goals
automatically goes in the VOSB goals
because you can't be a Service Disabled Veteran
without being a Veteran and that's one of the things we
try to educate individuals that anything that you
enter in your SDVOSB goal or accomplishment is the
same thing you need to put in addition to your veteran
because again you can take credit for that in both
places, you can't be a services abled veteran
unless you're a veteran and that's not
double counting.

It's important you
all understand that. Sometimes what is we try
to explain to people it's really good if you can
get one business that's HUBZone, Woman Owned
Small Businesses, Service Disabled Veteran because
then you get to meet four targets, you get the
HUBZone, you get the Woman Owned Small Business,
you get your Veteran goal, and you get
your SDV goal. And that is because
each one of those goals is a million dollar
contract and each of those categories you can put
the one million dollars because have you awarded
a million dollar contract to each one of
those categories.

Okay. So again, I would not
beat this contract up for missing two goals
because they've exceed in other areas, and they did
diligently, they did try to award to contractors. We would want to make sure
that whatever the basis is that they started
doing their subcontract, they continue, and
there's three bases but there's two
primarily used. Commitment basis when they
award the subcontract, they take
credit for it. This particular company
uses a payment basis so they don't take credit
for subcontracting accomplishments until they
have paid the invoice, which is great.

That way they don't have
to ever back out dollars. They've also certified the
daily basis at is accurate and it belongs to them
and not the lower tier subcontractors. If they had not then,
again, we would reject the report. If we notice that all of
their other reports were on a commitment basis
and now they're doing a payment basis we will
rejects the report because whatever you start
reporting on, is what you have to continue
to report on. We would then read what
was in their remarks column and according
to them, their period performance
consisted of three months of operation and
one and half months of close out. While actually overall,
Small Business and Small Disadvantaged
Business, Women Owned, and Veteran Business percent
were significantly exceed the plan goal, HUBZone Service
Disabled Veteran actually in overall spend
was below the goal.

Give the short period of
contract, the first goals did not have business
need nor the procurement opportunity to utilize
some of their small business vendors to the same
extent as they have historically. So according to them,
they just didn't have any opportunities to do more
than what they did. But, you know, we
definitely should applaud them because what they
would do, they did do. I also would applaud
them for giving us an explanation of why. We then ask again for
the contractor who administered because let's
say the opposite of this happened, they didn't meet
their goals, we should have started
communications way before the time of their
final report.

The ISR report is due
every six months, or as six-month
interview. At that point and time when we
get the report we need to be reviewing it to see if
they're on target to meet their goals because the
report is inception to date of
the contract. So we can tell whether
or not they're on target to meet their goals whether
it's the first year, second year, third year,
fourth year and at some point in time we need to
start communicating with them to address why
haven't they had any subcontracting, why
they're not on target to meet their goals, so that
they'll know that we're paying attention to the
data that's on the report and that we're here to
assist them if they need us to help them look for
vendors if they don't quite understand, or
maybe there's no more opportunities where
they thought they had opportunities.

You know, maybe we have to
come up with creative ways for them to do some
subcontracting with the small business. But we don't want to wait
till the final report to ascertain there
was a problem. When we realized
they didn't have any subcontracting or
weren't meeting their goal, perhaps we should have
done something then. What is peculiar to me is
they're saying that their report was only during a
three-month time frame, so I'm wondering do they
have a three month contract in which they only had
this one report? But, you know that would
— that would also take into account because
if they had a one year contract, even though
their performance was only for three months,
they still need to report that they had no dollars
during that other time frame. Because remember, whether
or not, you've had any subcontracting
accomplishments, you still need
to report. If this was a firm that
was not meeting those goals during that time
frame, I would have rejected the report to ask
if I could assist them.

Could they explain to
me why they're having shortfalls in this area,
explain to me what would be their plan of action,
so that we could kind of assist them in anything
they need to do during this time frame. The next thing we would do
again is ask for e-mail address. When we ask for the e-mail
address again, it does not mean if they do not put
your e-mail address there that you will not
get the report.

You still will get the
report as long as you are registered through the
proper contracting office. Again, if you find that
you have reports that have been submitted and you
cannot view those reports you just need to contact
your agency coordinator and your point of contact
to let them know that you cannot visibly
see your reports. Okay? Now that we've completed
the ISR portion, I kind of want to give
you information about assistance whenever
you need help with — whenever you need help
with the eSRS reporting. At the bottom of the
screen, these are live links, and these are live
links to the various types of reports that
are in the system.

And they give you
hands-on instructions on how to
review reports. I mean they give you
verbatim information. So if you were reviewing
an ISR, you would click on the ISR review, it will
open up in different window, and as you review
it, it will tell you — it has a table of contents,
but it tells you what the contractor's
responsibility is, it tells you what the
government responsibility is, it tells you what to
look at as you review the reports, it tells you
the time frames that the reports are supposed to
be reviewed, it tells you about the statuses of the
reports, it tells you how to enter into eSRS, it
tells you about that queue that I told you when you
first log on to eSRS where you should be seeing some
type of reports there if you were told
subcontracting reports were submitted to you, and
it gives you screenshots of every screen that you
would — your contractor sees when is
they're awarding.

So if you need to
assist your contractor, they contact you and say "Hey,
I'm having some difficulty understanding how to
navigate through eSRS," all you need to do is look
at this training material. It shows you, this is a
screen of your contractor, how they file the report,
and it gives you in-depth information about what
they see on the report so you have
never to guess. Anything that your
contractor is seeing, you see and it gives you
verbatim word for word what that is. It also tells you when
something is not right, when to reject, when
to accept the report. It tells you — and I'll
show you that as well. Here, like the verified
data, like I told you, if it doesn't say yes, it
says no, it tells once the information has been
corrected and resubmitted then you can have the
contractor go in and report and accept
the report. So at any time you need
assistance within eSRS, the training material
is here to let you know or to assist you in what
your role is in reviewing or to assist you in
getting your subcontractor or prime contractor assistance
with the eSRS system.

And again it's
listed here. One of the things that I
would like to show you and I'm going to show you
another training material is considered
generating reports. In eSRS, we have standard
reports that will let you know the statuses of the
reports that have been submitted in eSRS. We have both standard
reports and we have both ad hoc reports. The standard reports
that are in eSRS, this particular training
material tells you what the information they
provide on that report. So if your boss ever tells
you, "Hey, I need some type of information out
of eSRS," and you're wondering whether or not
eSRS has reports for that, the only thing you need to
do is log on to eSRS, look for the report that said
generate a report, review it to see if the reports
that are there provide with the information
you need. As well as it gives you
step-by-step information on how to run
the reports. The numbers that
correspond to the picture are the same numbers
that correspond to the information below
the picture.

Okay? So I'm going to show you
how to look at a report that will show you the
status of the reports that you have in the system
in case you're wondering if you have any reports
at all that you need to go into the system and
take out a pending status. Please keep in mind your
agency does not get any credit for their
subcontracting accomplishments for any
report that is not an accepted, acknowledged
receipt status. If it's in pending status,
revived status, reopen status, your agency will
not get subcontracting credit on their
annual report. So it's very important
that we go in this a timely manner
and correct that. The rules and regulations
now that has been finalized say that
government employees need to do that within 60 days
of — 60 days of the submitted report. In order to run that
report, you get on reporting. You would go to the bottom
of the screen and hit new. I'll show you this. When whenever you have
run a report, eSRS automatically states
that report for you.

If you want to review that
report again, you would click on the magnifying
class and as you scroll your mouse over it tells
you what these icons do. This is to review the
latest run of the report. This is to change or edit
the report settings. This is to rerun the
report, regenerate it. This is to see all previous
runs of the report. And this is to delete that
report out of your queue because you don't want
to see it here anymore. For the sake of the
presentation, I am going to run a new
status report.

Now when I run status
report, the status report is a standard report and
standard reports you can't really change any
of the settings. There are allow you to
filter on some settings. But to run, there's two
steps, can you either run step one is ad hoc reports
or step two, we call them predefined or
standard reports. That means we have already
predefined the criteria for the report. For the sake of this
training, we're going to look at an SSR status
report, because as you know we are getting ready
to do the score card and you really need to make
sure your agency SSR reports are in
acknowledged receipt accept a status in order
for to you receive credit.

As you can see, the
filter, I mean, everything is
already preselected. It does allow you to
select if you want to see children
agencies. HHS is considered a parent
agency and any agency that's under HHS is
considered a child agency or one of the
children agencies. You can filter on
a type of plan. If you select nothing
you get all reports. For the sake of this,
we're not going to filter on
anything. We will filter on — we
won't filter on date submitted but if you
wanted to know everybody who submitted their
report in November, can you do that. If you want to filter
on reports that were submitted only as prime
contractors verses subcontractors, you
can you do that. Please keep in mind
whenever you select both, both means that is a
report of a contractor who is both prime and
sub for your agency.

I recommend you do not
select any of these filters. The only filter that I
recommend that you select is if you want to see a
report for a specific year. For this particular
session, I'm going to put 2014 reports, because we
want to see every report that was submitted
for fiscal year 2014. Okay, so the agencies for
this report is predefined so when I run this report,
you will see other agencies outside of HHS,
but we're just going to focus on HHS. If you want to remove
this report out of queue, while it's being ran, you
could hit that button, but for me I want to see it so
I will hit view report, I'm going to scroll
down to HHS' reports.

Let me show you the
headings before I do that. At the heading, you will
see it gives you accepted reports, pending reports,
rejected reports, reopen reports, revised
reports, and total. Keep in mind if it's in
revise, reopen, rejected, or pending, you do not
receive credit for that report on your
subcontracting accomplishments
for your agency. When we look at HHS'
reports we see you have 298 reports
in pending status. You have a total
of 400 reports. You have accepted
96 of them. Have you five in
revised status and one in rejected
status.

Okay. I'm going to show you one
more report, if you want to know how your
agency is doing, for in subcontracting
accomplishments for fiscal year, we do have a
standard or predefined report you can run for
that as well but before I do that I want to show you
the functionality you can use within the report. If you wanted to
regenerate that report because somebody just said
"Hey, I had a contractor say that they" — or a
contracting officer say they just cleared the
queue and you want to verify that, can you just
hit regenerate the report, it goes back out and
regenerates the report again.

If you want to open this
report in a new window because you want to
do something else, can you do that. If you want to save
this data into an Excel spreadsheet, you
just click on the save Excel and it will generate
the information in an Excel spreadsheet so
can you utilize the functionality
of Excel. Okay. And there
you are. So now you can utilize
any of the functionality within Excel, maybe
do another report for your senior. If you want to change the
setting of the report, you know, you can do that,
maybe you want to run it for an
additional year. If you want to go back to
the report list which I want to do because I want
to show you how you can get your agency's
subcontracting accomplishments, you would
do — back to report list, again we would come
down to add now report, we would go to the predefined
reports, but this time we would do subcontracting
achievements by federal agency, we would
hit continue, again it is predefined report so
all of the filters have been chosen for you we will
choose fiscal year 2014 and we will only want
to see HHS totals.

So let's see you want
to do not just HHS as a whole, maybe you just
want to do your office, you can do that. Whenever you see this blue
arrow, that means there are sub agencies
also listed. So can you run this for
your particular office if you would
like to do so. If you made a mistake,
all you have to do is click the X and it will remove
that agency from your queue. I'm going to run the
success for the agency of HHS and all I do
is hit submit. This report will tell me
how you've done in small business, large business,
and every social economic category for taking 2014,
taking into account that it is only going to bring
in the report have been in accepted status. Okay? So we broke it down per
agency, office, for you all. And at the bottom it gives
a total for HHS as a whole. The end of the
presentation is pretty near, the only thing I
wanted to show you now is if you ever need any
subcontracting assistance, or eSRS assistance,
eSRS is managed by the Integrated Acquisition
Environment in the Integrated Acquisition
Environment Help Desk or the Electronic Subcontract
Reporting System is the Federal Service Desk.

There are several things
can you do on the federal service desk. You can actually have an
800 number where you can contact the 800 number and
you can make those calls and talk to a live
person or, you can put in a report through
the web form. Everyone who does a web
form will have to register for an account and they do
that so that if you ever have a question that you
need to revisit, you can just log onto your accounts or
revisit that information. In addition to that if you
ever need just frequently asked questions, they have
live links here that will allow you to go to the
system that you had those questions for. Again, eSRS questions, you
will go into eSRS and it will give you an overview,
user menu, samples, videos quick start guides as well to
provide you any information. This is system
navigational help. If you pushed a button and
the button didn't work or if you are looking at
a report and the report doesn't show your data
correctly, that is the kind of information that
you would go to the Federal Service
Desk for. If in fact you were
needing assistance on subcontracting help,
you need some type of information on
subcontracting assistance, at that point in time,
you would contact your commercial marketing
representative, who works for the small business
administration.

Your commercial marketing
representative could be found here, we do have the
presentation where it goes straight to the web site,
where you can look at your commercial marketing
representative by designated area. If you live in Missouri,
Michigan, you would look for your commercial
marketing representative by your area or your
state, it would provide you with their name,
telephone number, and contact information,
and your commercial marking representative will help
you any information you may have on subcontracting
as a whole. If all else fails, my
name is Angella Terry and as stated I am the
Subcontracting Program Manager for the Small
Business Administration. If you ever need any
assistance with any subcontracting question,
can noncontact me at angella.terry@sba.gov. >> Teresa Lewis: All
right, Angella, I just wanted to say
thank you. This was extremely
informative. Subcontracting is an
area where there's always, we always get a lot of
questions in the Small Business Office and
there's quite often some confusion on who actually
approves which reports.

So have you provided great
clarity today on that. So I just want to thank
you, on behalf of not HHS OSDBU, but all the OSDBUs
because this is something we all share
in common. So what I do is I will
go to the questions. While we're waiting for
that can you clarify one of the types of reports
that you shared? There are two types of
subcontract summary reports, one is for
commercial plans, one is for
individual plans. And we often get a lot of
questions on what's the difference between the two
is this if you can share that while I pull
up the questions.

>> Angella Terry: Okay, no
problem, so the difference between the two is as I
stated the commercial plan is a commercial
organization who sells a commercial product
has already elected to do subcontracting
with small businesses and social economic
categories. So that organization
has developed their subcontracting
plans, so to speak. It could be on a plan,
plants, product whatever, but it is specific to
that organization and has nothing to do
with the government. So at some point in
time when they decide to do contracting with the
government, they submit their proposal and let the
government know we sell a commercial item and
we already developed a commercial plan. The government reviews
that plan, decides "Okay, it's
acceptable to us." One of the major things is
a commercial plan is only good for fiscal year. It is not good for
the inception of the contract so
to speak. In addition to that,
the commercial plan when they report, they
report accomplishments on the plan which is not
specific to the government and that's so
important.

As can you see the report
that we looked at had zero dollars had
given HHS 35 percent. HHS had not even issued
a contract to them, so HHS attributable should have
been zero, but they should have had some
subcontracting dollars on the report
itself. So that is the major thing
with the commercial plan. Commercial plan is one
of the most difficult reporting plans that we
have because there is the contractors are really
confused on what the expectations are on
that particular plan. >> Teresa Lewis: Very good.

>> Angella Terry: The individual
report or individual plan is total different. It is specific to a
contract and it lasts for the inception of
the contract unless modifications are done
on the contract that increases it for the
subcontracting threshold. In that case, the plan
stays in place throughout the contracts inception. When you report, you're
reporting on specific to the contract and
to the government. Unlike the commercial
plan is specific to the organization's
subcontracting efforts. So those are the major
differences between the two. >> Teresa Lewis: Okay, you stated
during your presentation that if another agency
issues the plan, that the — commercial plan in
particular, that the contracting officer should
get a copy of that plan.

>> Angella Terry: Most definitely. >> Teresa Lewis: And I think there's
a lot of confusion as to — as a contracting
officer, is that my responsibility, to get
a copy of the plan? >> Angella Terry: Most definitely. So when they submit their
proposal to you, they should be submitting
a copy of their plan. If your solicitation
has a requirement for a subcontracting plan,
the contractor should be submitting a copy
of the plan with it. The difference is, if you
are the first government agency that that
contractor is pursuing a government contract then
you're going to be the approver of that plan. If you are the secondary
government, third or four, then you're accepting that
plan as is because some other government
organization has already accepted and
approved that plan.

However, you are looking
at that plan as it relates to your particular
contract. And therefore when
they report their subcontracting efforts,
you're also looking at the percent that they have
given you attributable for your agency and it is very
important if you for some reason are not in
agreement with that that you contact that other
agency who is the approving agency to allow
them to know to reject the report on your behalf
or to accept the report on your behalf. >> Teresa Lewis: Okay, so I'm going
to throw you a little curve ball.

I, being the contract
officer, have awarded a task order on the GSA
schedule contract. Now, my contractor,
Mr. Large Business has a commercial plan. I don't have to get a copy
of their plan from GSA, or do I? >> Angella Terry: Again you should
have gotten a copy of the plan when you
got the proposal. If you have a requirement
for a subcontracting plan, when they submit that
proposal to you, that's when they're submitting
a copy of their plan.

What comes in question
is, are we the first government organization
that is awarding your contract or not. >> Teresa Lewis: Okay. Okay. So we get a lot of
questions on, if it is a GSA task order contract
that I as the contracting officer here at HHS or
any other agency that has ordered off that contract,
I don't have to monitor the subcontracting
achievements on my task order because that's
GSA's responsibility.

>> Angella Terry: Well, think of it
this way, and let me make sure, if it is a GSA
contract, they're absolutely correct. If it's a GSA contract
that GSA is the contract holder of the base
contract, then GSA will be responsible for reviewing
the subcontracting actions of that contract. >> Teresa Lewis: Okay. >> Angella Terry: However because
you're issuing a task order on that, you would
want to see what that contractor has agreed
to do, and if you are in question of that, can
you always contact GSA and say, "Hey, we're issuing
a task order on this, and we would like to talk to
you about this particular commercial plan." They're right in fact
to say the GSA has the responsibility for that
contract because, again, it's a GSA contract,
however, they're incorrect in saying that they do not
have any responsibilities.

Again your organization
is awarding it, you want to be involved with what
that contractor is doing on that task order. You want to ensure
that the contractor is definitely giving
small business some opportunities on that
because they're doing work for you and they're not
actually doing work for GSA. The administrative portion
could be GSA's responsibility. >> Teresa Lewis: Yeah, we typically
tell the contracting officers here at HHS
that they actually have an responsibility to ensure
at the task order level that they are applying the
GSA goals on that task order and that they need
to ensure that for that respective task order
that they are actually monitoring our prime
contractor for those goals in that
particular task order. Okay. All right,
very good. Well, thank you
that's very helpful. So I'm looking at all
of the complements that you're getting and they're
saying "nice job," "kudos," and,
"thank you." So, let's start with some
of the questions that have come in because I could
talk to you all day.

You're so knowledgeable
and it's just wonderful to hear you provide clarity
in this subject area. So here's a question,
"Where again is the step-by-step information
in eSRS for ISR, et cetera?" >> Angella Terry: Okay. So again you can look at
this information from the portal,
http://www.ESRS.gov. On the right hand side,
training material will give you step-by-step
instructions on actual subcontracting. It gives you a
Subcontracting 101. I always tell people if
you can just read that one section, you'll be a
whiz at subcontracting. You'll be able to answer
pretty much any question that a contractor
may have for you.

In addition, at the bottom
of any screen that you're in in eSRS, there are live
links that will give you step-by-step instructions
on the review. I also wanted to mention
we're going through subcontracting regulations
changes and we have several changes that
relate to task orders, and subcontracting plans
as it relates to them. So when I get back to my
office, if you would, I would like just to provide
you with a lot of updates with that information that
we can share with the audience — >> Teresa Lewis: Thank you. >> Angella Terry: — in
reference to that. >> Teresa Lewis: Very
good, very good. So let's see, we — "Can
you repeat your e-mail address?" >> Angella Terry: Sure: angella,
A-N-G-E-L-L-A, . terry, T-E-R-R-Y,
@sba.gov. E-mail is the best way to
communicate with me and you might even get a
response at 11:00 at night because I'm always on my
BlackBerry trying to make sure I don't miss
answering someone's question. >> Teresa Lewis: Okay.

So, "is there, Angella,
an eSRS POC list for each agency that's
available?" >> Angella Terry: Yes. So as I was showing you
in eSRS, can I — >> Teresa Lewis: Absolutely. Please try. >> Angella Terry: So within eSRS, you
have contractors and have you agency and forgive me
for not navigating this so let me do
that now. So this is the eSRS tool
bar once you logged in and this is the government
section, any announcements that GSA integrated
acquisition environment or some government agency
wants you to know will be in the
announcement stage.

Reports will be reports
that have been submitted, individual will be that
individual subcontract report, summary will be
your both individual summary report and as
well as commercial, and then have you your
year-end SEB reports. Then have you contractors,
these are all contractors that are registered indeed eSRS
and then have you agencies. So when you we talk
about contact agencies you can look at from
the organization and if you look for the organization's name, you can go to
the core data tab and you can search,
excuse me, can you search by organization.

Once you search by
organization, it then gives you a listing of all
the contacts within that organization. >> Teresa Lewis: Very helpful. >> Angella Terry: And it also tells
you whatever role that they have in eSRS. You then can actually
search by role, you can search for agency
coordinators you want to look for, contracting
officials, designated government users,
POCs, super users. You can look
for that. If you know the person's
name you're looking for, all have to do is go to
keyword and enter any portion of that name and
hit search and it will provide you with
that information. >> Teresa Lewis: Angella, I think
that's very helpful. You mentioned earlier that
when a contracting officer takes over a contract
while — as long as they're registered
within that organization, they can see those contracts
but — those reports, but knowing who to contact
when there is a change or a transition, knowing
where to go, that listing is very helpful.

>> Angella Terry: Yes. >> Teresa Lewis: Okay,
very good. So let's see what additional
questions we have. All right, let's see, "are
simple small purchases, material and supply items,
considered subcontracting?" >> Angella Terry: So the simple
answer to that is anything that you don't provide for
yourself that you have to procure outside
is a subcontract. Simple. You know if you're a prime
contractor and you have to go outside of your
organization to procure an item, to complete the
work on this contract, it is considered
a subcontract. >> Teresa Lewis: Okay, very good. "In what type of contracts
would the eSRS be used? Would this be used
in R&D contracts?" >> Angella Terry: Research
and development? >> Teresa Lewis: Yes. >> Angella Terry: eSRS is not
specific to any type of contract other than if
the government issues a contract that meets
the threshold of 600 — and that threshold will go
up soon, of $650,000 for service and supplies
or 1.5 million for construction, it meets
the threshold for subcontracting plan
requirement and therefore must have a
subcontracting plan.

>> Teresa Lewis: Very good. "When a contractor submits
an ISR in eSRS," we love the acronyms, "contracts
specialist or officer reviews and accepts or
rejects the reports. When a contractor submits
an SSR in eSRS, who reviews and accept or
reject the report?" and this is a common
question across the federal agency. >> Angella Terry: So definitely the
commercial plan — excuse me guys, the contracting
officer, the individual is agency specific. So if your agency is —
has elected that the contracting officer
reviews the individual summary report, then it is
the contracting officer. If your agency has dreamed
someone else and then it's someone else, but
definitely the contracting officer is responsible
for the commercial plan. >> Teresa Lewis: Okay, so I want
to make sure we clarify.

We're talking about in
the case of subcontract summary reports. There are two types, one
for commercial plans, one for individual plans and
the one for the commercial plans, it is indeed the
contracting officer's responsibility to
approve or reject? >> Angella Terry: Yes ma'am. >> Teresa Lewis: Okay so that
clarifies things. As knowledgeable as I
thought I was about subcontracting, I always
thought it was OSDBU's responsibility to either
approve or reject the commercial subcontract
summary, so you have provided great clarity and
I just want to say thank you for that.

I hope for the rest of you
that that actually helps a lot as well. Okay, so "I have seen
SRS reports for eSRS. Is it possible for a
government agency to enter a subcontract plan or
plan goes in eSRS.gov?" >> Angella Terry: No, unfortunately
at this point in time, subcontracting plans
are not electronic. We are doing some
revamping to eSRS and maybe something that will
happen in the future. But at this particular
time, it is not. The plan does
not go into eSRS. >> Teresa Lewis: Okay, very good
so I'm getting a lot of questions about copies
of the presentation and if you look to the right of
the screen you'll see wording that says
training slides. You can click on that and
the presentation, the power point presentation
is there, however, keep in mind that Angella gave a
live presentation from eSRS. Now, the video, this
webcast will be made available on fai.gov. So you will actually be
able to see the video as well as Angella's
PowerPoint presentation on fai.gov probably within
the next couple of weeks.

Okay, so we've received
a lot of questions, very popular. Let's see. We just answered that one,
here's another one. "How does FAR 52.204-10
apply with contractors who have received an
award over $25,000? Does this clause apply to
small businesses who have subcontractors at a value
over $25,000 and the contract is over $50,000
and the prime has subcontracted the workout
to a contractor for $25,000?" Just wondering how
this clause applies to small
business. >> Angella Terry: So first of all,
everyone 52.204-10 is for FFATA, Federal Accounting
and Transparency Act, and has nothing to do
52.219-9 of FAR, which is the Small
Business Act. However, so I don't like
answering questions that have nothing to do with my
privy, however I will tell you that if you need
to have any questions answered off of FFATA, you
can go to the helpdesk, the http://www.fsd.gov.

Which — FFATA is ran from
GSA and they will answer that for you as well. >> Teresa Lewis: Well I'm glad you
said that because I was going to ask you about the
sub award reporting if that data was actually
extracted from FFATA, and so, I guess I have to go to
the federal service desk, Angella, to get
that clarification. >> Angella Terry: I do know the data on
FFATA is on USA Spending. >> Teresa Lewis: All right,
very good, very good. So Loretta gave you
a shout out from Fiscal Service, just
want to let you know.

Let's see, all right,
any new questions? "Is a subcontracting plan
required using FAR 13.5 simplified acquisitions
test program? In the FAR it states,
$650,000 for negotiated contracts, FAR
part 15." >> Angella Terry: So initially
I'm going to say yes. It is my understanding
that any contract that meets the threshold of the
$650,000 or 1.5 million required to have a
subcontracting plan. However because I do not
do work on 13.5 simplified acquisition, I will go
back and ask the powers that be which is Ken Dodds
of our Small Business Regulation Policies
Department, to ensure that I am correct. But my hearand now answer
is any contract that meets the threshold is required
to have a subcontracting plan unless it was issued
to a small business. >> Teresa Lewis: Okay. Very good. And so Angella once
you get that response if you provide
it to us. HHS in the process
gathering of all of the Q&As from all of our
training series, each of our training presentations
and we're going to include them on the
HHS web site. Those will not be on
fai.gov, at least not yet, but the webinar itself
will be as well as the training slides.

So your responses we will
definitely include with all of the — with all of
the questions that we have received today, we will
definitely include them. So Angella, let me
see if we have any additional
questions. This is really great,
there's a lot of interest, and we knew that
there would be. And it looks like from all
over the country you're getting a lot of requests
where there's a lot of interest. So, "If we have problems,
with the eSRS system who can I contact to
get it resolved?" >> Angella Terry: So we'll contact
the Federal Service Desk, it's http://www.fsd.gov. Again, fsd.gov, is the
Federal Service Desk that's managed by the
integrated and acquisition environment, which is
GSA, and they handle any technical issues you
will have with eSRS. If in fact your question
is a subcontracting question, they cannot
answer that, they don't do policy.

You would need to contact
SBA and you can either contact your commercial
marketing representative or again contact
me directly. >> Teresa Lewis: Okay, very good. So one thing I heard you
share with us today is share how important it is
to communicate with the — with our prime contractors
throughout the year and not just wait until
the end of the year. >> Angella Terry: Yes. Most definitely. It is very important. Kind of, you know,
especially for those commercial plan holders
because the IRS, you know, you will get them in six
months intervals, so you will look at it and see
what they're doing. You also know you have
until the end of the contract period to make
sure they're doing what they're supposed to do and
they're meeting their goals. Remember, the commercial plan
is only for a fiscal year. And they're only going
to report at the end of the
fiscal year. So you want to kind of
start some communications with them three months —
every quarter perhaps to make sure they're on
off-track meeting their goals and they don't have
any short falls they're aware of because perhaps
you can intervene.

Perhaps they need to look
for contractors and you know you can help them do
some market research to get that. But if you wait until the
end of the year, it's too late for
that period. >> Teresa Lewis: Yes. >> Angella Terry: Yeah. >> Teresa Lewis: And you also talked
a lot about the remarks section of the report. >> Angella Terry: Yes, most
definitely, please keep in mind, as I said earlier,
back in the day we had a paper based process where
papers got lost, contract files got lost, we closed
down things, stayed on my desk, somebody
else's desk. We now use the electronic
system to document. I always tell me
contractors and training that when they're
documents something to us, they use the remarks bill
and I ask them to put a date prior to their
comments, and I ask the government to do the same
in the reject notice or the accept
notice.

So it will be in the body
of that particular report indefinitely so that if
anyone else comes in, we change hands with the
contract responsibility, that individual will have
that data so they're aware of it. >> Teresa Lewis: Very helpful
and very helpful, and something I never thought
about and want thank you for this tidbit, and that
is ask the contractor if they need training,
if they need assistance. I don't think we
often think that "Hey, our primes actually
may have some questions and confusion." So I definitely think
the more we can open the dialogue around this,
the more that not only at HHS but across the
federal government we can achieve our
subcontracting goals. And the more we achieve
our subcontracting goals, the more opportunities
there are for small businesses and that is
what we're all here to do. So very good. Very good. So here's a question,
"Some contractors have an old company name on a new
ISR, but the new company name is correct
in sam.gov." Interesting.

>> Angella Terry: So — go. >> Teresa Lewis: I'll finish and
then I'll throw it at you. "And the contract was
novated to change the name of the company and the
new name is in the government
agency system. How does the contractor
get the new name on the new ISR?" That's an interesting
question. >> Angella Terry: Yeah it is. So the system is built
this way, once a company has a novation agreement,
the old company is no longer there, however
that old company did have a contract in eSRS, they
did have reporting requirements within eSRS,
so therefore that report needs to
stay there. They no longer report
on that old contract, they now need to go into
an eSRS and report on the new
contract. >> Teresa Lewis: I see,
I see. Okay, very
interesting. It looks like we have
a few more questions. More complements Angella,
they're loving it. You're doing a
fantastic job. So again,
thank you. Let's see if there's
anything else. If anyone has any
additional questions, this is a
great time.

Angella is extremely,
extremely busy giving she's providing oversight
across the entire federal government so I'm feeling
fortunate to have you here so it's a great
opportunity to get your questions out. So while we're waiting for
additional questions, I will just throw a
couple others at you. Indirect dollars, you
mentioned that, and I may have captured this
incorrectly so I'll ask you to clarify, so, if the
prime contractor reports that they have included
indirect dollars, is it the contracting officers
responsibility when they are reviewing the
subcontracting — the eSRS report that they're
to deduct the indirect, the amount of the indirect
dollars from the amount of dollars that were reported
as subcontracted, or did I get
that incorrect? >> Angella Terry: So the contracting
officer can never deduct anything. They can never do that
because they don't know what portion of the dollars
are indirect dollars. However it's two different
types of reports, so let's talk
about that. If it's the ISR report,
it is governed by the subcontracting plan. So if the subcontracting
plan says indirect dollars is included then
they're included.

If the subcontracting plan
says indirect dollars are not included and the
contractor says indirect dollars were included, we
reject the report and say please remove your
indirect dollars. >> Teresa Lewis: And that's why
it's important for the contracting officer
to have a copy of the subcontracting plan when
they're conducting the review. >> Angella Terry: Correct. >> Teresa Lewis: As you
stated previously. >> Angella Terry: Right. But there's
Catch 22 to that. When it comes to the
summary report, the FAR does state that a prorated
portion of the incorrect cost should be included
in the summary reports.

>> Teresa Lewis: Okay. >> Angella Terry: And we've
had questions from contractors, trying to figure
out how do I calculate that. And what we try to tell
them is just prorate it over the life
of the contract. >> Teresa Lewis: Okay, so the
contracting officer however does
not have a role. Okay. >> Angella Terry: There only role is
to verify on that ISR that indirect cost is either
supposed to be on there or not supposed
to be on there. >> Teresa Lewis: And according to
the subcontracting plan. >> Angella Terry: Yes. >> Teresa Lewis: Very good. All right, so
here's a question. "How responsive are
government agencies in compliance with
subcontracting reports? In other words are they
just checking the box? If they are just checking
the box, does SBA have a way of monitoring
the reality of the subcontracting plan?" >> Angella Terry: Okay, well I would
hope that every government agency is serious about our
regulations and requirements.

It is very — this
administration has made it very clear how they
support small business. And the subcontracting
program is how we ensure small businesses receive
government guess. So I would like to think
that every agency is serious about that. However, SBA definitely
monitors and I would be that monitoring individual
in which I do sporadically look at reports, and I
look at reports to see whether or not someone is
meeting goals, on target to meet goals, I look at
the commercial plan report to make sure the dollar
figures are somewhat accurate. Especially the percent
attributable if they're giving you 99 percent, I
know there's issues there. So SBA definitely does
some monitoring however we hold it up to the agencies
because it will be the agencies that will be
held accountable through Congress and the President
when it comes to their small business
dollars.

>> Teresa Lewis: Absolutely. And I can tell you at
HHS that subcontracting is a very important
priority. And that's one of the
reasons we're having this training because the way
that the regulations are written, and I recognize
that you don't write the regulations, but the way
that they're written, they can be
confusing. So there are many
contracting officers whose really have an
intention to do the right thing but the information
is somewhat confusing so having you here to
clarify it goes a long way, Angella.

And I want to say again,
you know, I know that I've been complementing you
throughout but I really if I you could just here
the questions in the Small Business Office that
we receive from contracting, you would understand
really how valuable this training is and in fact
you have a complement from GSA, they say "Good job
from GSA here in D.C." >> Angella Terry: Thank you. >> Teresa Lewis: All right, so
here's a question. "Are small businesses
exempt from being required to sub commit
subcontracting plan regardless of the dollar
value of the contract? For example, a three
million dollar contract for a small
business?" >> Angella Terry: Yes.

Yes, they are. >> Teresa Lewis: Yes, they are. But I do want to address
the 52.219-A which is the inclusion or small
business participation — >> Angella Terry: And limitations of
subcontracting as well. >> Teresa Lewis: Yeah, definitely. >> Angella Terry: That they must do
at least 51 percent of the subcontracting on awards
they are provided. >> Teresa Lewis: Definitely. >> Angella Terry: Right. >> Angella Terry: I'm sorry. And guys, believe it or
not small businesses police other small
businesses, so if they find out that some small
business got awards a contract and gave it to
a large business they're going bring to it to
someone's attention. And when they bring that
information to your attention, just as bait
and switch when a large business say "Hey,
I'll going to give you a contract" and they
don't get the contract, those are things that you need
to bring to our attention and definitely to the
head of you contracting attention because we do
have rules and regulations that stop those
types of actions.

>> Teresa Lewis: Well you know
what I think is going to be very helpful for federal
agencies is, the like kind credit that a small
business that for example is a HUBZone that
subcontracts to a HUBZone that the federal
agency can — >> Angella Terry: Get
credit for it. >> Teresa Lewis: — exactly, at that
subcontract level and the prime level for that
HUBZone, so that not only encourages small
business to use other small businesses that are
like kind, but it also gives the
agencies credit.

So it's really a
win-win for everybody. So I think
that's great. And I know that
was your idea. I know that was your idea
as to why they put that in there. So very good. So here's a
question. "Will there be any time in
the future that you are the current subcontracting
plan, copy of it scanned, for example, could
be uploaded to eSRS? This would be — this
would help a contracting officer ensure accurate
reporting to the contract door." >> Angella Terry: So we have the
integrated acquisition environment has a change
control board and every agency has someone who
sits on that board.

I would recommend you
finding who is the person that sits on the
CCB for your agency. What they do is they
represent your agency, whatever system that is
ran by IAE, if you require some type of enhancement
to that system to make your job easier, it's
their job to put a change request into
the system. The more change requests
we have for a certain feature definitely
increases the — right, you know the ability
for us to do it. We do know that, you know,
that subcontracting plan is definitely would be a
major thing if we could get it electronic so you
don't have to go look for it when it's time to
review that report. I can't say for certain
whether or not that is something we have agreed
on it, right now because I haven't look indeed JIRA, but
I can tell you, if you can communicate with your integrated
acquisition environment CCB rep, they will be able
to tell if you, not they can put a request
in for you.

>> Teresa Lewis: Okay,
thank you. So a couple more questions
before we let you out of here. There's one, "is a
subcontracting plan required to be submitted
from AbilityOne?" >> Angella Terry: Yes,
yes, yes. And that is one that has
been at the forefront. Believe it or not
AbilityOne is willing to do that my encounter,
with that was with GSA. GSA wanted to understand whether
AbilityOne was supposed to be doing a subcontracting
plan and they are, and they're not
exempt from that. And believe it or not if
you talk to AbilityOne they will have no
problems with doing a subcontracting plan. >> Teresa Lewis: Okay, very good. So, another
question. "When awarding BPAs or IDIQs,
when do we submit the eSRS?" >> Angella Terry: eSRS reports are —
I don't really understand that question so let me
say this, whenever you — whenever you award a
contract, you enter that contract in FPDS-NG.

If a subcontracting
plan was required, you definitely click
subcontracting plan is required. Whenever you issue any
task order or whoever was awarded, that particular
IDIQ, BPA, or whatever, they are supposed to
report when reports are due and they report
on the base contract. >> Teresa Lewis: Okay. All right. So, "What authority
does SBA have to assist a small business when a
prime closes the business without paying them
for work performed?" >> Angella Terry: Oh wow,
that's horrible. Definitely you need
to contact SBA. You can either contact
Government Contracting And Business Development if
you don't know anyone within Government Contract
And Business Development, contact me, you can
contact PCR, contact the CMR, but you definitely
need to let somebody in SBA know and we will
reach out and assist a small business anyway we can. Because that's definitely a
violation of the regulations. >> Teresa Lewis: Exactly. And if you
don't know — >> Angella Terry: It's really the
Prompt Payment Act.

>> Teresa Lewis: Exactly. And if you don't know whom
at SBA to reach out to, please reach out to your
Small Business Office and we can assist you with
finding someone at SBA. >> Angella Terry: In fact, that
should be the first person they reach out to. >> Teresa Lewis: Yeah,
absolutely, absolutely. Okay. So, Angella we have gone
over — this is great and I'm not complaining at
all, it's very important to all of us that
the individuals. Our contracting officers
are our primary stakeholders and we work
in tandem with them to provide maximum
opportunities for small businesses so having you
here has been a delight. There have been a lot of
questions regarding your COPs, your continuing
learning points, and the answer is
absolutely yes. What we do at HHS is
we ask individuals to preregister in FFATAS,
we are working closely to them, to ensure your
records are update with the CLPs, 1.5 CLPs,
for this session are updated to
your profile. If you did not
preregister, it's okay.

Because you did register
for the webinar on the webcast site and we will
then get that information from our webcast
contractor, and we will ensure that FAI also
receives that information. If you are participating
on this — on this training as a group, then
what can you do is contact your agency career manager
and just have that individual provide us at
sbmail@HHS.gov with the listing of those
individuals, and we will ensure that everyone
receives proper credit. So, Angella, I'm going
to conclude the webcast hesitantly because it's
been so wonderful. We've had significant
interest and like I said that, you know, providing
the clarity on our role as the acquisition personnel
and approving, rejecting, you know, taking the status
or making a decision on those subcontracting
reports is really critical and it's going
to go a long way.

I thank you. You are welcome anytime if
you have new information that you want to share,
and you are always welcomed at HHS. Everyone, I just want
to thank you again for participating and we will
send an announcement out shortly for
our next webcast. We just want to thank
everybody again for joining
us today. Thank you. >> Angella Terry: Have a
great day. Thank you..

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