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Subcontracting & The FAR – Beyond the Basics

October 18 @ 2:00 pm - 3:30 pm

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Whether you are a small business prime contractor, or a large company seeking small business participation at the subcontractor level, you have to understand the requirements in FAR Part 19 lest you risk losing the work, or worse, you could face suspension/debarment and civil and criminal fraud charges. What makes it all the more confusing is that FAR Part 19 is inconsistent with 13 CFR, the Small Business Administration’s regulations, in a number of respects. So when it comes to these small business questions, who can you trust? SBA or the FAR? What are the implications? And how do you not only ensure compliance, but even use the rules to give yourself a competitive advantage? Join Bill Walter and Cy Alba as they discuss the ins and outs of FAR Part 19 as well as the key issues you need to know when working as, or working with, small businesses.

Subcontractors play a vital role in the federal market place, but they also face a number of challenges. This series will go beyond the basics and get down to specifics regarding the key rules and regulations in the FAR to help contract mangers and subcontractors alike navigate the choppy waters around all manner of subcontracting challenges. Our instructors will interpret the policies and procedures on subcontracting and explain various issues in a business-friendly manner. Specifically, the instructors will address, among other things, the FAR clauses on advance notification and when consent is required, flowing down contract modifications, defining and using commercial items; small business subcontract requirements, limitations on subcontracting rules, and development of a subcontracting plan. Further, we will delve into the labor standards for contracts as dictated by the Service Contract Act and the Davis-Bacon Act, equal opportunity requirements, and, even decode the mystery of Cost Accounting Standards and how it impacts the administration of subcontracts.

  • Session 1 – Sept 20
    1. Subcontracting Overview
    2. Subcontracting Policies and Procedures FAR Part 44
      • Advance Notification IAW FAR 52.244-2
      • Request for Consent IAW FAR 52.244-2
  • Session 2 – Oct 4
    1. Subcontracting and FAR – Part 12
      • Supplier’s Commercial Item Determination
  • Session 3 – Oct 18
    1. Subcontracting and FAR Part 19 Small Business
      • Small Business Subcontracting Plan or letter from Subcontractor with approval of IAPWS SBLO of non-applicability if FAR 52.219-9 is in prime contract
      • FAR 52.914-14 Limits on Subcontracting
  • Session 4 – Nov 1
    1. Subcontracting and Subpart 22.4 Labor Standards for Contracts Davis-Bacon and Related Acts (DBRA)
      • The Service Contract Act and Davis Bacon Act for Subcontractors
      • Submitting Certified payrolls (Davis Bacon Act)
      • Submitting Price Adjustments
      • Subcontracting and Subpart 22.8 Equal Employment Opportunity (Including the Pre-Award Letter)
      • Conducting Investigations as a Subcontractor
      • Notifications in Construction, FAR 52.222-23
  • Session 5 – Nov 15
    1. Part 30 Cost Accounting Standards Administration
    2. The latest on executive compensation reporting requirements
      • Accounting and Billing Certification
      • Certificate of Current Cost or Pricing Data
      • Cost Accounting Applicability
      • Types of CAS Coverage
      • Cost Accounting Standards (CAS) Representation and Certification
      • Notification of an Award of a Subcontract to Cost Accounting System (CAS)


October 18
2:00 pm - 3:30 pm
Event Category:


John Plinke

The Public Contracting Institute is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

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