I don't know the specific technical issues associated with implementing this approach, nor do I possess all of the expertise or knowledge required to chart out the pro's and con's for small business, prime contractors, or government agencies. However, it's potentially a pretty reasonable and viable starting point that makes more sense than some of the ideas coming off the Hill.
At least that's what I'm told by the those I've discussed it with who possess the wherewithal (soup to nuts) to help move this forward.
We're already talking with friends and associates in acquisition-related positions (operations and policy) as well as those intimate with the FAR and CFR's to determine how this might shake out and what levels on both sides, need to be involved.
Sorry, I don't mean to be cryptic. What I'm referring to is including small business subcontracting as line items on the contracts awarded to prime contractors with a dollar amount (not an award fee) associated with each CLIN. The concept is pretty straightforward. Don't deliver, don't get payed. Just as in the case of other CLIN's for goods and services, these deliverables would be agreed upon by the prime and the government agency. In this case it would be a blend of what small business participation the agency expects, and what the prime signs up for. The Small Business Subcontracting Plan would effectively represent one or more CLIN's on the resulting contract.
There are plenty of details to work out, such as what "monies" would be associated with the CLIN(s)? Personaly, I think giving someone an award (fee) for something they are supposed to do is silly, so in this case, perhaps the value of the subcontracted work is the amount associated with each CLIN. If the prime does not deliver as they committed in their plan, even if the work has been completed, then they forfeit that dollar amount. For example, if the prime chose to give the work to a company that was "other than small business" then they can pay that company from its own coffers versus the taxpayer's pocket. It's an idea.
The good news is, the folks giving this idea merit are considering it based on the impact and best interests of Government agencies, Small Business, Prime Contractors and you and I, the Taxpayers.
The Chief Visionary
"The person who says it cannot be done should not interrupt the person doing it."
I am all for mechanisms to ensure that small businesses get a fair shake in the federal contracting arena (being one myself). However, I believe mechanisms already exist. What is needed is that one word that sums up the missing link in many of these issues: ACCOUNTABILITY.
I have seen contracts structured such that parts of it (i.e. sections of a SOW are to be done by small businesses, and thus the CLIN would be integrated with the small business subcontracting plan required per Federal Acquisition Regulation Part 19). However, it is the enforcement that I rarely see.
What happens to a large business that submits a compliant subcontracting plan to get in the door, then does not actually follow through in percent work and dollars to be performed by small businesses? My experience is very little.
Isn’t this what performance-based contracting, or incentives for that matter, is all about? There should be metrics, measures, and of course, the surveillance and enforcement (e.g. acco