FAR 19.705-6—Postaward responsibilities of the contracting officer.
Plain-English Summary
FAR 19.705-6 lays out the contracting officer’s postaward duties when a contract or contract modification includes a subcontracting plan, or when an existing plan is amended. It covers the required notifications and document transmittals to the SBA, including notice of award, forwarding commercial plans and approvals, providing plans to the SBA procurement center representative, and notifying the PCR about contract modifications. It also requires the contracting officer to send plans or no-plan determinations to the cognizant contract administration office. Beyond paperwork, the section assigns ongoing oversight responsibilities: monitoring subcontracting report submission in eSRS, reviewing ISR and SSR reports on time, acknowledging or rejecting reports, evaluating good faith effort and explanations for missed subcontracting use, initiating liquidated damages when warranted, and enforcing contract terms when the contract administration office raises compliance issues. In practice, this section is the postaward compliance framework that keeps small business subcontracting commitments visible, reviewable, and enforceable throughout contract performance.
Key Rules
Notify SBA of award
After award of a contract or modification containing a subcontracting plan, the contracting officer must send a copy of the award document to the SBA Area Director in the area where the contract will be performed. This gives SBA timely notice that a subcontracting plan is in place and allows oversight to begin.
Send commercial plans to SBA
For commercial plans, the contracting officer must forward a copy of each plan and any associated approvals to the SBA Area Director in the area where the contractor’s headquarters is located. This ensures SBA has the approved commercial plan and can track the contractor’s overall subcontracting performance.
Provide plans to the PCR
The contracting officer must give the SBA procurement center representative a copy of any subcontracting plan submitted in response to a sealed bid solicitation and the final negotiated plan incorporated into a negotiated contract or modification. If no PCR is assigned, the contracting officer must follow the alternate procedure in 19.402(a).
Notify PCR of modifications
When a contract modification creates an opportunity to review subcontracting plans, the contracting officer must notify the SBA PCR, or use the 19.402(a) alternate if no PCR is assigned. This keeps SBA involved when the subcontracting plan may need to be revised or reexamined.
Send plan or no-plan determination to CAO
The contracting officer must forward a copy of each subcontracting plan, or a determination that no subcontracting plan is required, to the cognizant contract administration office. This supports contract administration oversight and helps ensure the administering office has the correct compliance record.
Monitor eSRS reporting
The contracting officer must monitor the prime contractor’s compliance with reporting requirements, including ensuring reports are submitted in eSRS within 30 days after the report ending date and reviewing ISRs and, where applicable, SSRs within 60 days after the report ending date. The officer must also acknowledge receipt of or reject the reports under subpart 19.7, FAR 52.219-9, and the eSRS instructions.
Reject only for report defects
A report may be rejected only if it is not adequately completed, such as when there are errors, omissions, or incomplete data. Failure to meet subcontracting goals is not a valid reason to reject the report, and if a report is rejected the contracting officer must explain the deficiencies so the contractor can respond.
Evaluate good faith effort
The contracting officer must assess whether the prime contractor made a good faith effort to comply with its subcontracting plan. If applicable, the officer must also evaluate the contractor’s written explanation for not using a small business concern in the same scope, amount, and quality used in preparing the bid or proposal.
Assess liquidated damages when warranted
If the administrative contracting officer recommends liquidated damages, or if other reliable evidence shows they may be warranted, the contracting officer must initiate action to assess them under 19.705-7. This is the enforcement mechanism for serious subcontracting plan noncompliance.
Enforce contract terms on CAO notice
When the contract administration office gives notice under 19.706(f), the contracting officer must take action to enforce the contract terms. This ensures that compliance issues identified during administration are addressed by the contracting officer with authority over the contract.
Responsibilities
Contracting Officer
Notify SBA of award; forward commercial plans and approvals to the SBA Area Director; provide plans to the SBA PCR; notify the PCR of contract modification review opportunities; send plans or no-plan determinations to the cognizant contract administration office; monitor subcontracting report submission and timeliness in eSRS; review ISR and SSR reports within required timeframes; acknowledge receipt of or reject reports; explain any rejection; evaluate good faith effort and written explanations for subcontracting shortfalls; initiate liquidated damages when warranted; and enforce contract terms when notified by the contract administration office.
SBA Area Director, Office of Government Contracting
Receive award notices for contracts performed in the area office’s jurisdiction and receive commercial plans and associated approvals for contractors headquartered in that area. The SBA uses these documents to support oversight of subcontracting plan compliance.
SBA Procurement Center Representative
Review subcontracting plans for sealed bid solicitations and final negotiated plans incorporated into negotiated contracts or modifications, and be notified when contract modifications create an opportunity to review subcontracting plans. If no PCR is assigned, the alternate process in 19.402(a) applies.
Contract Administration Office
Receive copies of subcontracting plans or no-plan determinations and provide notice under 19.706(f) when enforcement action is needed. The office supports administration and compliance monitoring.
Prime Contractor
Submit subcontracting reports in eSRS within 30 days after the report ending date; provide complete and accurate ISR and SSR submissions; respond to any rejection with corrected or clarified information; and comply with the approved subcontracting plan and its goals in good faith.
Administrative Contracting Officer
When assigned, recommend whether liquidated damages should be assessed based on subcontracting plan noncompliance or other reliable evidence.
SBA eSRS system
Serve as the reporting platform for ISR and SSR submissions and the place where the contracting officer reviews, acknowledges, or rejects reports.
Practical Implications
This section is as much about administration as it is about enforcement: missing a notice, transmittal, or eSRS review deadline can weaken oversight and create compliance gaps.
Contracting officers should separate report quality from performance results; a contractor can miss subcontracting goals and still submit an acceptable report, so rejection is only for incomplete or defective reporting.
Good faith effort matters. Officers should document the basis for their evaluation, especially when subcontracting goals were not met or when the contractor explains why a small business was not used as planned.
Liquidated damages are not automatic; they require a supportable basis and should be initiated only after the required review and evidence gathering.
Contractors should expect close postaward scrutiny of both reporting timeliness and substantive compliance, so internal tracking of eSRS deadlines, subcontracting commitments, and supporting records is essential.
Official Regulatory Text
After a contract or contract modification containing a subcontracting plan is awarded or an existing subcontracting plan is amended, the contracting officer shall do the following: (a) Notify the SBA of the award by sending a copy of the award document to the Area Director, Office of Government Contracting, in the SBA area office where the contract will be performed. (b) Forward a copy of each commercial plan and any associated approvals to the Area Director, Office of Government Contracting, in the SBA area office where the contractor’s headquarters is located. (c) Give to the SBA procurement center representative (or, if a procurement center representative is not assigned, see 19.402 (a)) a copy of- (1) Any subcontracting plan submitted in response to a sealed bid solicitation; and (2) The final negotiated subcontracting plan that was incorporated into a negotiated contract or contract modification. (d) Notify the SBA procurement center representative (or, if a procurement center representative is not assigned, see 19.402 (a)) of the opportunity to review subcontracting plans in connection with contract modifications. (e) Forward a copy of each plan, or a determination that there is no requirement for a subcontracting plan, to the cognizant contract administration office. (f) Monitor the prime contractor's compliance with its subcontracting plan, to include the following: (1) Ensure that subcontracting reports are submitted into the eSRS within 30 days after the report ending date ( e.g. , by October 30 th for the fiscal year ended September 30 th). (2) Review ISRs, and where applicable, SSRs, in eSRS within 60 days of the report ending date ( e.g. , by November 30 th for a report submitted for the fiscal year ended September 30 th). (3) Either acknowledge receipt of or reject the reports in accordance with subpart 19.7 , 52.219-9 , Small Business Subcontracting Plan, and the eSRS instructions ( www.esrs.gov ). (i) The authority to acknowledge or reject SSRs for commercial plans resides with the contracting officer who approved the commercial plan. (ii) If a report is rejected, the contracting officer must provide an explanation for the rejection to allow the prime contractor the opportunity to respond specifically to identified deficiencies. (g) Evaluate the prime contractor's compliance with its subcontracting plan, to include the following: (1) Assess whether the prime contractor made a good faith effort to comply with its small business subcontracting plan. See 19.705-7 (b) for more information on the determination of good faith effort. (2) Assess the prime contractor's written explanation concerning the prime contractor's failure to use a small business concern in the performance of the contract in the same scope, amount, and quality used in preparing and submitting the bid or proposal, if applicable. (h) Initiate action to assess liquidated damages in accordance with 19.705-7 upon a recommendation by the administrative contracting officer, if one is assigned, or receipt of other reliable evidence to indicate that assessing liquidated damages is warranted. (i) Take action to enforce the terms of the contract upon receipt of a notice from the contract administration office under 19.706 (f). (j) Acknowledge receipt of or reject the ISR and the SSR in the eSRS. Acknowledging receipt does not mean acceptance or approval of the report. The report shall be rejected if it is not adequately completed, for instance, if there are errors, omissions, or incomplete data. Failure to meet the goals of the subcontracting plan is not a valid reason for rejecting the report.