1. Small Business Liaison Officer (SBLO) 101 and 102 Training
DoD Western Regional Council for Small Business Education and Advocacy
Raul Alvarado
SBLO – The Boeing Company

2. SBLO 101 SBLO 102 AGENDA AGENDA Common Acronyms Why?
Categories of Small Businesses
Reporting Requirements
Small Business Subcontracting Plans
AGENDA
Small Business Subcontracting Plans
Small Business Compliance Reviews
DLA 640
SBA Preparation Checklist
Management Commitment
Training

3. Common Acronyms NAICS SIC SB LB SDB WOSB HUBZONE VOSB SDVOSB FAR DFAR
SBA
ID/IQ

4. WHY SMALL BUSINESS Amendment to SB Act (PL 95-507) - Passed in 1978
Required Federal agencies to establish small business goals and provide an explanation to Congress when goals were not met.
Established a OSDBU Office at each contracting agency
Redefined minority firms as “Socially and Economically Disadvantaged Small Business Concerns”
Established subcontracting plan for large businesses
Reserved all awards under $25,000 for small business

5. WORLD OF SMALL BUSINESS
SMALL DISADVANTAGED BUSINESS (SDB)
WOMAN OWNED
HUBZone
VETERAN OWNED
8(a) SMALL BUSINESS
SERVICE DISABLED VETERAN OWNED BUSINESS
Historically Black Colleges & Universities and Minority Institutions (HBCU/MI)
Javits-Wagner O’Day (JWOD)
AbilityOne

6. SMALL DISADVANTAGED (SDB)
DEFINITION - A SDB is small business firm that is 51% owned, operated and managed on a daily basis by individuals who are socially and economically disadvantaged.
Socially Disadvantaged
Presumed to be socially, racially, ethnically, or culturally disadvantaged or subjected to racial or ethnic prejudice or cultural bias
African Americans
Hispanic Americans
Native Americans
Asian Pacific Americans
Subcontinent Asian Americans
Other minorities as defined by the SBA
13 CFR
Economically disadvantaged
Individuals denied access to capital and credit opportunities because of their identification as a member of a specific group
Personal Net worth must be less than $750,000 excepting
Ownership by the principal(s) in the firm
Equity in the primary personal residence

7. SMALL DISADVANTAGED BUSINESS
To represent itself as a SDB for Federal contracting, a firm must have:
Submitted application to the SBA
Received certification from the SBA that it is a SDB
For reporting purposes, a firm may not self-certify as a SDB -- if the SDB firm is NOT in the SBA’s database ( then the firm is not counted as SDB.
FAR deviation

8. SBA’s 8(a) BUSINESS DEVELOPMENT PROGRAM
Two-stage program:
Developmental stage
First 4 years
Emphasis on sole source contracts
Strengthen financial & managerial skills
Improve access to markets
Transitional stage
Last 5 years
Emphasis on competition
Overcome remaining elements of economic disadvantage
Prepare to graduate program
NOTES:
THE OBJECTIVE OF THE PROGRAM IS TO ASSIST SDB. FIRMS IN ENTERING THE FEDERAL CONTRACTING ARENA AND IN OBTAINING CONTRACTUAL EXPERIENCE WITH FEDERAL AGENCIES.
A FIRM CAN STAY IN THE SECTION 8(a) PROGRAM FOR NINE YEARS. THE DEVELOPMENT STAGE IS FIVE YEARS. IN THIS STAGE THEY RECEIVE MAINLY SOLE SOURCE CONTRACTS BUT ARE ENCOURAGED TO COMPETE.. 9 9 9 3 8 8 7

9. WHO IS ELIGIBLE FOR THE 8(a) PROGRAM?
Individuals who have been certified by the SBA as socially disadvantaged (refer to the previous SDB statement) and,
Economically disadvantaged
Personal & business finances examined
Access to capital/credit
Entry level - less than $250,000 in personal net worth
Rises as they progress in program
NOTES:
NATIVE AMERICANS: AMERICAN INDIANS, INDIAN TRIBES, ESKIMOS, ALEUTS, NATIVE HAWAIIANS
ASIAN PACIFIC AMERICANS: JAPAN, CHINA, PHILIPPINES, VIETNAM, KOREA, SAMOA, GUAM, LAOS, CAMBODIA, TAIWAN, BURMA, THAILAND
SUBCONTINENT ASIAN AMERICANS: ASIAN INDIAN - INDIA, PAKISTAN, BANGLADESH, SRI LANKA, BHUTAN, NEPAL
OTHER MINORITIES: DETERMINED ON AN INDIVIDUAL BASIS - CAN INCLUDE CERTAIN HANDICAPPED PEOPLE AND IN SOME CASES VETERANS OF THE VIET NAM ERA.
ECONOMIC DISADVANTAGE: SOCIALLY DISADVANTAGED INDIVIDUALS WHO WERE DENIED ACCESS TO CREDIT OPPORTUNITIES BECAUSE OF THEIR IDENTIFICATION AS MEMBERS OF THESE GROUPS. PERSONAL NET WORTH: LESS THAN $250,00 AT ENTRY -AMOUNT CAN RISE TO $500,000 IN DEVELOPMENT STAGE AND $750,000 IN TRANSITION STAGE. 10 10 10 4 10 10 8

10. WOMAN OWNED BUSINESS (WOSB)
DEFINITION - A WOSB is small business firm that is 51% owned, operated and managed on a daily basis by individuals who are women.
Congress has mandated that DoD award 5% of contract dollars to WOSB.
The Small Business Reauthorization Act of 2000 (P.L ) allows WOSB set-asides (permissive, but not mandatory).
Implementing regulatory guidance is currently being examined by the SBA.

11. Historically Under-Utilized Business Zones (HUBZone)
Four Requirements to be a qualified HUBZone :
Must be a registered small business
Concern must be owned and controlled only by US citizens 51% owned and controlled by US citizens
The principal office of the concern must be located in a HUBZone; and
At least 35% of the concern’s employees must reside in a HUBZone
The HUBZone Empowerment Contracting Program is a community-based economic development program designed to stimulate: Job creation and Capital investment -- in distressed areas

12. VETERAN OWNED SMALL BUSINESS (VOSB)
DEFINITION - A VOSB is small business firm that is 51% owned, operated and managed on a daily basis by one or more veterans. In the case of publicly owned businesses, at least 51% of the stock must be owned by veterans.
Veteran - A person who served in the active military, naval, or air service, and was discharged or released from service under conditions other than dishonorable.

13. SERVICE DISABLED VETERAN OWNED SMALL BUSINESS (SDVOSB)
DEFINITION - A SDVOSB is small business firm that is 51% owned, operated and managed on a daily basis by one or more service disabled veterans. In the case of publicly owned businesses, at least 51% of the stock must be owned by service disabled veterans.
Service Disabled Veteran - A veteran with a disability that is service connected as defined in Title 38 U.S.C. Section 101(16).

14. HBCU/MIs
Historically Black Colleges and Universities (HBCUs): Term used to identify accredited institutions of higher education established prior to 1964 with a principal mission of educating African-Americans.
Minority Institutions (MIs): Term used to identify institutions, in addition to HBCU, having significant minority enrollments. Designated minority groups include African-Americans, Asian-Americans, Alaskan Natives, Hispanic/Latino-Americans, Native Americans, and Pacific Islander-Americans.

15. NATIVE AMERICAN FIRM
DEFINITION – An Indian-owned enterprise is commercial industrial or business activity established for profit with at least 51% Indian ownership
Ownership can be:
Individual – where the majority owner(s) are of Native American descent
Tribal - any Native American tribe, band, pueblo, or community, including native villages and native groups as defined in the Alaska Native Claims Settlement.
Native American firms are not a SB category in the “standard” set of categories to these firms
Native American includes American Indians, Eskimos, Aleuts, and Native Hawaiians.
Thus Alaska Native Corporations (ANC), Native Hawaiian Organizations (NHO), and Tribal Corporations (TC), are all considered Native American Firms
There are nuances associated with Alaskan Native, Tribal-Owned and Hawaiian Native Organizations that affect
Eligibility rules
Procurement rules

16. Reporting – SBLO 101 ISR (SF294) – Report on Individual Contracts
FAR (d)(10)(iii)
Semi-Annual
To DCMA, SBA, Contracting Officer
SSR (SF295) – Report on Agency Contracts
Was Semi-Annual – ** New ** UPDATED in Federal Register
To DCMA, SBA, Washington, DC
October 1, 2008 – All Agencies on e-SRS

17. Reporting – SBLO 101
Opt312 – or equivalent – ** New ** UPDATED by FAR Deviation
Yearly with SSR (SF295)
With Final ISR (SF294)
Other
As requested by Customer or Agency
Semi-Annual Mentor-Protégé
FAR (d)(10)(ii)

21. CCR

22. CCR

23. How Many DUNS Do You Have?

25. ISR = Individual Subcontract Report (FKA SF294)
New Acronyms
DRT = Draft
PEN = Pending
REJ = Rejected
ISR = Individual Subcontract Report (FKA SF294)
SSR = Summary Subcontractor Report (FKA SF295)

26. Small Business Subcontracting Plans
Plans – SBLO 101
Small Business Subcontracting Plans
Types
Comprehensive
Commercial
Master
Individual

27. Comprehensive Commercial Test Program through 2014 Negotiated annually
Plans – SBLO 101
Comprehensive
Test Program through 2014
Negotiated annually
Commercial
Products sold to general public or industry at established catalog or market prices
Contractor’s fiscal year

28. Contains all required elements of an individual plan except goals
Plans – SBLO 101
Master Plan
Contains all required elements of an individual plan except goals
Must be approved by
Corporate Administrative Contracting Officer (CACO)
Company Authorized Signature
Covers a period of 1 to 3 years
Individual Subcontracting Plan
In conjunction with a Master Plan
Specific to a contract – covers entire POP
Has goals based on Offeror’s planned subk effort
Prorated allocation of indirect cost allowed (if applicable)

29. SBLO 102 1

30. Why do we have these plans?
What is a subcontracting plan?
What are the required elements of a plan?
Developing the Subcontracting Plan – the Process, tips

31. Why do we have these plans?
“It is the policy of the United States that SB, SDB, WOSB, VOSB, SDVOSB, HUBZONE concerns have the maximum practicable opportunity to participate in the performance of contracts awarded by any federal agency. Other-than-small business (OTSB) contractors are legally obligated to carry out this policy when awarding subcontracts to the fullest extent consistent with the efficient performance of their contracts.” SBA Handbook for Small Business Liaison Officers
FAR and (1)
Any solicitation over $650k requires a clause for subcontracting plans.
If a negotiated award value (including options) is anticipated to be over $550k, any large business being considered for award, is required to submit a subcontracting plan as part of their proposal.
$1 million for construction
The Small Business Act (added by P.L )
Implementation is in FAR
Clause is in FAR
Additional implementation and clauses in FAR Sups 2

32. Exceptions to this requirement for plans?
FAR (2)(b)
Small Businesses
Contracts being performed entirely outside of the U.S. (including U.S. possessions – meaning it’s states or territories. Washington, DC and Puerto Rico are INCLUDED)
Modifications to contracts which do not contain clause 3

33. What is a subcontracting plan?
“A subcontracting plan is a document setting forth how a contractor will provide SB, SDB, WOSB, VOSB, SDVOSB, and HUBZONE SB concerns with the maximum practicable opportunity to participate in the performance of a contract or subcontract.” SBA Handbook for Small Business Liaison Officers
A document submitted by a prime contractor which details what they will subcontract on large prime contracts. Specifically, what will be subcontracted to SB, SDB, WOSB, HUBZSB VOSB, & SDVOSB.
FAR

34. Sample Subcontracting Plan
SBA Handbook for Small Business Liaison Officers
- Appendix C – also has a Sample Subcontracting Plan

35. Major elements of a subcontracting plan…
FAR (d)(1) thru (11)
Goals must be expressed as percentages of total planned subcontracting dollars
A statement of total dollars planned to be subcontracted to:
SB SDB WOSB HUBZone
VOSB SDVOSB 6

36. Major elements of a subcontracting plan…
Description of the principal supplies and services to be subcontracted, and
Identify the SB, SDB, WOSB, HUBZSB, VOSB, & SDVOSB’s that the products and services will be subcontracted to.
A description of the method used to develop the subcontracting goals.
A description of the method/process used to identify potential sources for solicitation
Source lists, SBA Dynamic Small Business Database (FKA ProNet), Trade Associations, etc.
A description of the efforts you will make to assure that SB, SDB, WOSB, HUBZSB, VOSB & SDVOSB have an equitable opportunity to compete for subcontracts. 7

37. Major elements of a subcontracting plan…
Assurance that you will:
Include the clause “Utilization of Small Business Concerns” in all subcontracts that offer subcontracting opportunities and require all subcontractors (except SB) who receive subcontracts in excess of $650k ($1.5 M construction) to adopt a plan that is in compliance with the FAR.
Cooperate in studies and surveys as required
Submit periodic reports to allow the government to determine compliance with the plan
Submit ISR (Individual at Prime Contract level) and SSR (Summary at Agency level) Subcontracting Reports
Ensure its subcontractors submit ISR and SSR 10

38. Small Business Compliance Reviews – SBLO 102
Prepare utilizing the DCMA Form 640
Prepare utilizing the SBA Checklist
May be joint audit by DCMA and SBA
DCMA – DoD Contracts
SBA – Non-DoD (NASA, DOE, EPA, etc.)
Annually for “Acceptable” and “Highly Successful”; Bi-Annually for “Outstanding”

39. Small Business Compliance Reviews – SBLO 102
Outstanding
Highly Successful
Acceptable
Marginal
Unsatisfactory

40. Small Business Compliance Reviews – SBLO 102
Common Issues
Areas of weakness
No documentation of assistance being provided to SB firms
Size certifications not being updated
Should be done annually on all, not just new
Policy & Procedures not updated to include new programs
Back-up for dollars reported on ISR/SSR
Training

41. Small Business Compliance Reviews – SBLO 102
Management Commitment
Policy Statement
Issued by current senior management
Disseminated throughout the company
Indicate that Small Business subcontracting is a company policy and is the responsibility of each person in the company having procurement or requirement responsibilities
Outlines authority for implementing SB program
Identify distribution and assure policy provides objectives of National Small Business policy

42. Small Business Compliance Reviews – SBLO 102
Management Commitment
Policy Letter
SBLO Appointment
Policy & Procedures
Awareness of Small Business Programs

43. Small Business Compliance Reviews – SBLO 102
Training
Procurement
Contracts
Program Office
Proposal Teams
Outreach
Conferences
Referrals
Assistance to Small Businesses

44. Small Business Compliance Reviews – SBLO 102
EXAMPLES OF OUTREACH
National Veteran’s Conference
SB Local or National Association Meetings
SBA Week – April/May
DoD Western Regional Council for SB Education & Advocacy – 4 times per year
Navy Gold Coast – August
NMSDC – October
MEDWeek

45. REPORTING 1

49. SPECIAL PROGRAMS 1

50. Purpose of the Mentor-Protégé Program
The Mentor-Protégé Program is designed to provide incentives for Prime Contractors to assist Small Disadvantaged and Woman-owned Businesses to enhance their business and technical capabilities and to increase their participation as subcontractors and suppliers.
The program shall also foster the establishment of long-term, mutually beneficial business relationships between protégé’s and mentors.

51. Types of Mentor-Protégé Agreement
Cost Reimbursable
Credit

52. Agencies that have Mentor-Protégé Programs:
Army
Navy
Air Force
DISA – Defense Information Systems Agency
DLA - Defense Logistics Agency
DOD
Energy
EPA – Environmental Protection Agency
FAA
Homeland Security
NASA

53. For your time and attention
SBLO 101 and 102
THANK YOU
For your time and attention