Compliance Questions and Answers.
When FAR 52.244-6 is included in noncommercial contracts, it identifies the
clauses to be included in what kinds of subcontracts?
Subcontracts for commercial or non-developmental items.
How will the inclusion of the flow-down clauses in CD 2018-O0021 or FAR 52.244-
6 impact post-award subcontracting compliance management? For all four
contracts, the procuring contracting officer (PCO) has delegated all contract
administration functions that can be delegated.
It is a best practice for the administrative contracting officer (ACO) to conduct a post-
award orientation conference and review the required flow-down clauses with the prime
contractor.
During post-award administration, we need to impress upon each prime contractor that
it is the prime contractor's responsibility to ensure that its subcontractors are complying
with the flow-down clauses.
Goal of Government Procurement
Small businesses should be provided maximum practicable opportunities to participate
in government procurements.
What is a first-tier subcontract?
A first-tier subcontract is defined in FAR 52.204-10 and means a subcontract awarded
directly by the prime contractor for the purpose of acquiring supplies or services
(including construction) for performance of a prime contract.
(Don't forget the useful job aid that was provided earlier that contains common terms
and definitions. It includes this term, first-tier subcontract, along with several others.)
Individual Subcontracting Plan
An individual subcontracting plan is a subcontracting plan that applies to a single
contract and has goals that are based on the offeror's planned subcontracting in support
of a single contract.
Master Subcontracting Plan
A master subcontracting plan is a subcontracting plan that is established on a plant,
division, or company-wide basis. It contains all the required elements of an individual
subcontracting plan, except goals. Then, when an offeror responds to a solicitation, it
submits the pre-approved master plan with a supplement that identifies the offeror's
subcontracting goals for the specific contract.
Commercial Subcontracting Plan
A commercial subcontracting plan is a subcontracting plan (including goals) that covers
the offeror's fiscal year and that applies to the entire production of commercial items
sold by either the entire company or a portion thereof, such as a division, plant, or
product line. The commercial subcontracting plan is the preferred plan when the
contractor is furnishing commercial items to the government. It includes the fifteen