Electronic Subcontracting Reporting System (eSRS) February 1, 2006
Electronic Subcontracting Reporting System (eSRS) The eSRS is an electronic, web-based system for subcontract reporting that will replace the SF-294 & SF-295 paper forms. When DoD comes on board in FY 2006, it will be a Government-wide system and the only automated system authorized for subcontract reporting.
Organizational Structure Systems Steward U.S. Small Business Administration (SBA) Contractor Symplicity Corporation, Inc. 8(a) firm based in Arlington, Virginia
System Features (cont.) Critical Systemic Linkages Central Contractor Registration (CCR) Federal Procurement Data System (FPDS-NG) Government-wide agency hierarchy DUNS numbers for prime contractors and subcontractors
IAE Architecture This diagram depicts the relationships between the agency systems on the left and the various IAE services in the gray boxes. It also shows the many other systems that IAE interfaces with to validate data or collect data
Electronic Subcontract Reporting System (eSRS) The eSRS is a downstream FPDS/NG application – On the Positive Side: If a contract contains a subcontracting plan and has been entered correctly in FPDS/NG, the eSRS automatically receives a record of it; The Downside: If a contract is not in in FPDS/NG or has not been entered correctly, the contractor won’t be able to enter his ISR (formerly the SF-294) report at all
Identifies contracts in FPDS-NG having subcontracting requirements System Features Business Processes Identifies contracts in FPDS-NG having subcontracting requirements Automates completion and submission of SF-294 and SF-295 Will include the Annual SDB Breakout Report (3-digit NAICS subsector) When fully operational, it will also automate the Optional Form 312
Goal Computation on the ISR The system calculates the achievements by two methods: % of contract value % of subcontracting ___________________________________ Note: the eSRS will only calculate the percentage on the achievement side, not the goal columns. This is by intent, because we want the contractor to copy the goals from the subcontracting plan exactly as they appear in the plan.
System Features (cont.) Provides breakout of subcontracting data down to the buying activity level. Generates standard and ad hoc reports Analysis of Subcontracting Plan Goal Attainment Five-Year Trend Table SBA Goaling Report for Congress & the President Several other standard reports Generates automatic reminder notices and delinquent notices.
Beta Testing and Acceptance Initial Operating Capability (IOC) Critical Milestones Beta Testing and Acceptance September 2005 Initial Operating Capability (IOC) October 28, 2005 Full Operating Capability (FOC) Target: 8 weeks after IOC
What Should Contractors Enter? (continued) Civilian agency contractors must use the eSRS for their Summary Subcontract Reports (SSRs) for the period ended September 30, 2004; and they must use the eSRS for both their Individual Contract Reports (ISRs) and their Summary Subcontract Reports (SSRs) for the period ended September 30, 2005
Do Contractors Have an Extension for Filing? OFPP memo dated Nov. 3, 2005, authorizes agencies to grant their contractors a 60-day extension for filing the 9-30-05 reports (60 days from IOC) Oct. 28th + 60 days + 3 Holidays = December 31st
What will FOC give us that IOC doesn’t? FOC will provide an application interface so that contractors with electronic systems of their own can simply upload their data into the eSRS (as opposed to keypunching it into the eSRS one report at a time)
Is the FAR being changed? SBA finalized a FAR case that includes changes to subpart 19.7 and the related clauses, especially 52.219-9 In the meantime, SBA’s Office of General Counsel has ruled that the eSRS is the electronic equivalent of the SF-294 & SF-295
FAR Case Revises subpart 19.7 and clauses at 52.219-9 & 52.219-25 to replace all references to SF-294, SF-295, and Optional Form 312 with eSRS. Revises the flow-down provision at 19.704(a)(9) and 52.219-9(d)(9) to require the prime contractor to flow the prime contract number down to the subcontractors at lower tiers prime contract number now becomes a mandatory field in the eSRS, even for subcontractors, in order to facilitate lower-tier reporting.
FAR Case (cont.) Moves “General Instructions” from the paper forms to the clause at 52.219-9. Requires contractors to print a hard copy of the Summary Report(s) and have them signed by the CEO. Contractor will be required to keep hard copy with CEO’s signature on file for 4 years. SF-294, SF-295, & Optional Form 312 will all be deleted from Part 53 – i.e., abolished!
FAR Case The Small Business Committee of the FAR Council will review and discuss the specific provisions in the proposal The regulation will be issued as a Proposed Rule or Interim Final Rule 60-day public comment period Final Rule will reflect changes resulting from public comments, as appropriate
Individual Subcontracting Reports (ISR) Prime Contract Number LOWER TIER REPORTING Individual Subcontracting Reports (ISR) Former SF 294 Prime Contract Number Higher Tier DUNS Product and Service Lines NAICS Email Address of the Govt Official to Review the Report No Inclusion of Lower Tier Dollars
LOWER TIER REPORTING Government contracts with Company X Contract Number DE-AC01-05EE12345 Company X will include on their Individual Subcontracting Report: Their Duns is 001339457 Prime Contract Number- DE-AC01-05EE12345 Company X subcontracts with Company Y Contract Number XX-05TP00023 Company Y will include on their Individual Subcontracting Report: Company X’s DUNS-001339457 Their DUNS-113456896 Contract Number with Company X-XX-05TP00023
LOWER TIER REPORTING (cont.) Company Y subcontracts with Company Z Contract Number YY-05DD99963 Company Z will include on their Individual Subcontracting Report: Company Y’s DUNS-113456896 Prime Contract Number- DE-AC01-05EE12345 Their DUNS-132568700 Contract Number with Company Y- YY-05DD99963
Summary Subcontracting Reports Summary Subcontracting Reports (SSR) Former SF 295 Product and Service Lines NAICS Email Address of the Govt Official to Review the Report No Inclusion of Lower Tier Dollars
REVIEW OF REPORTS Government will review: Prime Individual Subcontracting Report All Summary Subcontracting Reports Higher-Tier Subcontractors will review: Lower-Tier Individual Subcontracting Reports
Accounting Methods “Commitment Basis”- means that you capture the transaction when you execute the subcontract award document. “Payment Basis”- means that you capture it when you pay the invoice. If you use some other method, or hybrid of the two, the system allows you to select “other.” Once you select the method, it can not change for the life of the contract.
Acceptance of Reports "Acceptance" does not mean approval, per se, but it does mean that the Government has reviewed the report and that it appears to be complete. Since an on-site compliance review later on could identify flaws in the preparation of the report, the Government always has the right to reject a report that has previously been accepted.
How will the eSRS Help Desk work? The Help Desk will handle all technical questions regarding the use of the eSRS E-mail address is Help@esrs.gov Questions regarding subcontracting policy will be referred to SBA Other problems/issues will be forwarded to the Agency Coordinator of the agency that awarded the contract
CCR Assistance Center 888-227-2423 FPDS-NG ISSUES TROUBLESHOOTING CCR ISSUES- CCR Assistance Center 888-227-2423 FPDS-NG ISSUES Call the Contracting Officer eSRS ISSUES Contact the eSRS Helpdesk
Contacts for Policy Questions The CMR listing at http://www.sba.gov/GC/cmr.html provides the names, addresses, phone numbers, fax numbers, and email addresses of SBA’s CMRs-roughly 36 people. Contractors using the eSRS who have policy questions should call their nearest CMR.