Research Administration Office

University of California

Memo Operating Guidance

No. 90-8

Supplement No. 1

May 17, 1994

Subject: NASA Requirement for Quarterly Reporting on Subcontracting Plans

On September 30, 1993, NASA published a final rule in the Federal Register that had the effect of adding a new clause to the NASA FAR Supplement, numbered 1852.219-75 and titled "Small Business and Small Disadvantaged Business Subcontracting Reporting." This rule changed the frequency of reporting on subcontracting plans on the SF 295 form from annual to quarterly, for NASA prime contracts containing subcontracting plans. It also contained a similar flowdown provision.

When the final rule was published, we informally alerted Contract and Grant offices via e-mail. However, this office continued to argue with OMB that the rule had not been properly reviewed and approved, and so we held off sending out a formal notification. After a telephone conversation with Peter Weiss/OMB today, it is dear that the political reality is not going to be overcome at this time. We will have to wait until the form comes up for re-approval in 1995. For the time being, then, we have no choice but to accept the clause 1852.219-75 in contracts where NASA requires it.

Refer: William Sellers

(510) 987-9847

william.sellers@ucop.edu

cc:

David Barnard

Materiel Managers

Small Business Coordinators

Kate Phillips/COGR

Subject Index: 16

Organization Index: F-615, U-115