July 18, 1990
Subject: Subcontracting Reporting Forms, SF-294 and SF-295
Federal Acquisition Circular (FAC) 84-58 authorized federal contracting agencies to use new subcontracting reporting forms (SF-294 and SF-295, copies enclosed) effective June 21, 1990. These forms replace the earlier versions that were dated 10/83 and should be used from now on.
In general, the information needed to be provided on these forms is the same as it has been in the past. The major changes are that SF-295 need only be submitted annually for non-DOD agencies (but still quarterly for DOD), and both forms now collect information on women-owned small businesses and, for DOD contracts, historically black colleges and universities (HBCUs), and minority institutions (MIs). Thus with the exception of the changes discussed in this Memo, the operating guidance issued in Section C of C& G Memo 82-4 (October 21, 1981) is still in effect.
An earlier draft of revisions in SF-295 indicated that colleges and universities might be exempt from SF-295 reporting requirements. Although some of the University's comments on the draft revised form were accepted, our suggestion that universities be exempt from SF-295 reporting requirements was rejected. The final version of SF-295 does apply to the University. Accordingly, C& G Memo 84-14 (May 1, 1984) is hereby canceled.
NEW DATA ELEMENTS
As indicated above, the SF-294 and SF-295 forms now include reporting on subcontracts with women-owned small businesses and (for DOD) HBCUs/MIs. The sections below indicate which boxes on the forms are used to collect this information. Campuses should develop procedures to be able to identify subcontracts (including subagreements for research) awarded to these types of institutions under those prime federal contracts that have subcontracting plans. Data on women-owned small businesses is collected for all such prime contracts; data on HBCUs/MIs is collected only when such contracts are awarded by DOD.
The following two sections of this Memo describe the changes that have been made in SF-294 and SF-295:
SUBCONTRACTING REPORT FORM FOR INDIVIDUAL CONTRACTS. SF-294
Standard Form SF-294, "Subcontracting Report Form for Individual Contracts," is a federal-wide form used to collect data on subcontracts made to small, small disadvantaged, and large business concerns under individual federal contracts in excess of $500,000 which include a subcontracting plan. Submittal of the form continues to be required on a semi-annual basis; agencies may not require a more frequent submission without specific approval from OMB.
The blocks on SF-294 have been re-numbered. Specific blocks that have been deleted, as identified under the OLD numbering scheme, are:
9. 11. 12. 16.a. (2)
9. Business Classification Code.
11. DUNS No.
12. Date of Last Government Review.
16.a. Reviewing Agency.
(2) data on Other Small Business Concerns.
Specific blocks that have been added, as identified under the NEW numbering scheme, are:
8. Type of Report (Regular, Final, or Revised).
11.B. Dates of Contract Period of Performance (From/To). Revised
12.B. Contract Amount (if applicable).
13.B. Revised Amount of Subcontract Awards Under Modified Contract (if applicable).
14. Revised Goals (if applicable). For DOD contracts you should include data for HBCUs and MIs.
Boxes to indicate whether goal amounts include or do not include indirect costs.
The instructions for filling in these new boxes are self-explanatory.
The following boxes have been revised (as identified under the NEW numbering scheme):
Reporting Period: Check one of the two boxes and fill in the appropriate federal fiscal year. The instructions say to leave this box blank if box 2. is checked "Final."
Same as OLD box 15.a., except for DOD contracts you should include data for HBCUs and MIs.
Same as OLD box 16.a. except you should include data for women-owned small businesses and, for DOD contracts, data for HBCUs and MIs.
Same as OLD box 16.b.
Same as OLD box 16.
Same as OLD box 16.a.(1) except for DOD contracts you should include data for HBCUs and MIs.
Same as OLD box 17.a.(2)
Same as OLD box 17.b.
Same as OLD box 17.a.(1)
NOTE: 17.A. through 17.C. are shaded to indicate they are only applicable to DOD contracts; however, for University purposes they would continue to be left blank under both DOD and non-DOD contracts because the University does not award any indirect subcontracts under federal contracts.
The "Remarks" section contains some additional instructions which are self-explanatory.
SUMMARY SUBCONTRACT REPORT
Standard Form SF-295, "Summary Subcontract Report," is a federal-wide form used to collect summary data on subcontracts made to small business concerns (including women-owned small businesses), small disadvantaged businesses (including, for DOD contracts, HBCUs and MIs), and large business concerns. A campus will continue to be required to submit SF-295 forms to each federal agency from which it has received one or more federal contracts over $500,000 that have subcontracting plans.
The reporting frequency for SF-295 remains quarterly when the report is to be submitted to DOD. For all other agencies the reporting frequency has been changed to annually.
The blocks on SF-295 have been re-numbered. No existing blocks have been deleted. Specific blocks that have been added, as identified under the NEW numbering scheme, are:
Type of Report (Regular, Final, or Revised).
data on women-owned small businesses (break out from box 11.A.) for DOD contracts only, data on HBCUs and MIs (break out from box 12.)
The instructions for filling in these new boxes are self-explanatory.
The following boxes have been revised (as identified under the NEW numbering scheme) .'
Reporting Period: For DOD agencies (e.g. AFOSR, ARO, ONR), check the correct quarter ending date in 1.A. and fill in the appropriate federal fiscal year. For all other agencies, check the ANNUAL box in 1.B. and fill in the appropriate federal fiscal year.
Contractor Establishment Code: Same as DUNS No.
Same as OLD box 9.a. including data for women-owned small businesses, except for DOD contracts you should also include data for HBCUs and MIs.
Same as OLD box 9 .b.
Same as OLD box 9.
Same as OLD box 10. except for DOD contracts you should also include data for HBCUs and MIs.
Same as OLD box 11.
Same as OLD box 12.a.
17.B.(1) Same as OLD box 12.b.
17.B.(2) Same as OLD box 12.c.
18 .A. Same as OLD box 13.a.
18.B. (1) Same as OLD box 13.b.
18.B. (2) Same as OLD box 13.c.
Block 14., Labor Surplus Area Concerns, would continue to be filled in as "N/A" because there is no regulatory reporting requirement for the University. Please refer to Section C of C& G Memo 82-4 for additional information on filling out SF-294 and SF-295.
DEPARTMENT OF ENERGY DEVIATION
The Department of Energy currently does things a little differently. In accordance with DEAR 919.708(b), DOE contracts over $500,000 that have subcontracting plans will include the DEAR clause 952.219-9, Small Business and Small Disadvantaged Business Subcontracting Plan -- Alternate. The effect of this clause is to eliminate the need to submit the SF-295 but to require quarterly submission to DOE of the SF-294. DOE has been doing this for at least five years, with the approval of OMB. If and when the agency revises its requirements we will let you know.
Refer: Bill Sellers, ATSS 8-582-1638, (415) 642-1638
David Haskins, 8-567-0470, (415) 987-0470
Subject Index: 16
Organization Index: F-005; U-115
Cancel: Memo No. 84-14
University Materiel Coordinator
David F. Mears
Research Administration Office
Small Business Coordinators