VETS GWAC Subcontracting Report Information
All Industry Partners are required to enter subcontracting data semi-annually by individual task order in the GWAC Management Module of ITSS (https://itss.gsa.gov). The reporting period runs from February through July with reporting due August 31st and from August to January with reporting due by March 1st. These reports are reviewed by the Small Business GWAC Center staff for compliance with FAR 52.219-14, Limitations on Subcontracting. These reports are a mandatory requirement of the contract. An industry partner’s failure to comply with this obligation will result in corrective action, i.e., performance improvement plan, option not exercised, and possible termination of contract.
It
is the Industry Partner’s responsibility to report in the GWAC
MM at http://itss.gsa.gov.
Reporting period: February 1 to July 31 Report Due: August 31
August 1 to January 31 February 28 (or 29)
Prime contract holders may count work subcontracted out to other SDVOSB contractors as their own work. Please refer to G.17 and G.24 of the contract, and also FAR 52.244-2. It is advisable to read the subcontracting information shared with OCOs elsewhere in this guide. Subcontractor approval is not required at the contract level.
Prime contractors are responsible for performing greater than 50% of the work at the contract level per 52.219-14, and should perform a meaningful amount on each order to prevent pass through situations
It is reasonable and routine that on larger tasks SDVOSB prime contractors may significantly rely upon capacity building through subcontracting with other SDVOSB firms, or other than SDVOSB firms, to provide scalability in the early stages of performance. It is reasonable to consider the total prospective life cycle of an order, including options, when evaluating how much work the prime and SDVOSB subcontractors, if any, plan to perform for a given task order. This life cycle perspective permits SDVOSB primes to use their judgment in teaming to fulfill customer requirements, and to manage the expected SDVOSB participation over the full span of an order.
For the applicable contract clauses, see your VETS GWAC contract or the Contract Library at www.gsa.gov/vetsgwac.
FAQs – Subcontract Reporting at ITSS.Gsa.Gov
1. I have no new task orders awarded on VETS GWAC contract; do I have to submit subcontracting information?
Yes. All subcontract information must be kept current.
Enter subcontracting information on each task order in the GWAC Management Module (GWAC MM) in the “Small Business Subcontracting Data” section of each task. To revise the data, use the “Edit” button.
2. I have no task orders. Do I have to report?
No, please report that information in your Quarterly Status Report
3. I have multiple subcontractors on a single task order, how do I reflect that on the report?
Enter each subcontract and their DUNS number in your task order at itss.gsa.gov in the “Small Business Subcontracting Data” section of the "Order Package.”
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4. Can I fax or email the report back to you?
No, please report in the GWAC Management Module of ITSS
5. What is the correct reporting period for this report?
Please see the Ordering Guide.
6. The email address listed in the SBGWAC Center’s files is wrong. What do I need to do to change it?
The contract manager (who is currently of file – check the industry partner list of the VETS GWAC website) or President/CEO must send an email to [email protected] or an e-mail with an attached letter requesting the change.
7. What about 1099 employees?
1099 employees are considered subcontractors.
8. Where can I find further information regarding the VETS GWAC and the FAR 52.219-14, Limitations in Subcontracting?
Go to www.gsa.gov/vetsgwac, Ordering Guide
Please contact the Small Business GWAC Center with any additional questions.
Small Business GWAC Center Toll-Free: (877) 327-8732
Tags: industry partners, the industry, report, subcontracting, partners, information, industry