Helping Businesses Grow & Succeed

State Designated as Florida’s Principal Provider of Business Assistance [§ 288.001, Fla. Stat.]

Form 640 Review

Gregory J. E. Sikosek Supplier  Diversity  Advocate    

   

About Your Presenter

Introductions

Name?

Business interests?

Expectations?

Seminar Objectives

To provide you: An Overview of what to expect in a DCMA conducted

Small Business Program Review; also known as the Form 640 Review

Small Business Program Review

Form 640 Review

Keys to Success

• Preparation • Presentation • Documentation • Management Support • Closing

Notification

•  The contractor notification letter requests specific information to be mailed or electronically forwarded prior to the actual review. This information is submitted by the contractor to the PA within 14 days prior to the scheduled review.

•  May be accompanied by a copy of the 640 Review Form

What to do First?

Preparation •  The specific information requested includes:

–  Completed DCMA Form 640, PART I –  A list of all DoD contracts which carry FAR requirement

52.219-9 for small business subcontracting plans –  Current company organization chart showing connection

from top Management to Supplier Diversity professional –  A list of all specific internal documents that show small

business program policy and procedures –  A list of small business outreach activities conducted

during the review period

2 TYPES of REVIEW

•  Comprehensive Subcontracting Plan – Limited Participation – Anticipated EOL in 2014

•  Individual Subcontracting Plans – More Common – Requires more individual reporting and more

contract level data

Forms

•  Defense Contract Management Agency (DCMA) Review of Contractor’s Subcontracting Program (DCMA FORM 640) – Usually provided by DCMA auditor in

advance – May provide a modified form

Presentation

•  Completed DCMA Form 640 •  PowerPoint Presentation AND Hardcopy Binder

for DCMA that follows the order of the form is a highly recommended best practice –  The presentation illustrates the success of your

Small Business Program and facilitates completion of the 640 form by the auditor

–  Each slide should present evidence of compliance with and performance against the standard

–  Build your case: take the opportunity to showcase your best practices

Documentation

•  Purchase Order Files with key documents

highlighted and tabbed •  Supplier Subcontracting Plans and copies of

ISR’s filed against the plans •  Terms and Conditions (e.g., eSRS) •  Supplier Status Certifications (e.g. HUBZone

record from SBA dynamic search site, annual certification forms)

•  Internal Policies and Procedures

Management Support

•  Do you have documented evidence of statements made by Executive Leadership that support Supplier Diversity Goals and Activities?

•  Do you have adequate resources dedicated to activities such as Small Business Conferences?

•  Do you have evidence of how you proactively search for small business sources? e.g., Memberships with NMSDC, WBENC, Participation in Conferences and Trade Fairs?

Closing

•  Summary of Key Takeaways from DCMA

Form 640 and Presentation •  Summary of Leadership Support •  Summary of Supporting Documentation •  Evidence of Commitment and Results

Reference Documents

•  CONTRACTOR’S SUBCONTRACTING PROGRAM REVIEW GUIDE (DCMA FORM 640) January 1, 2004 – http://guidebook.dcma.mil/

37/640ProgramReviewGuide.doc

Additional Information 1.  FAR Part 19.7 Small Business Subcontracting Program 2.  FAR 42.302, Contract Administration Functions 3.  DFARS 219.201, General Policy 4.  DFARS 219.7, Subcontracting with Small Business, Small

Disadvantaged Business, and Women-Owned Small Business Concerns

5.  DoDD 4205.1, DoD Small Business and Small Disadvantaged Business Utilization Programs, September 11, 1996

6.  FAR 52.219-8, Utilization of Small Business Concerns 7.  FAR 52.219-9, Small Business Subcontracting Plan 8.  FAR 52.219-16, Liquidated Damages - Subcontracting Plan 9.  FAR 52.219-26, Small Business Participation Program-Incentive

Subcontracting 10.  DCMA/Small Business Administration (SBA) Memorandum of

Understanding, May 9, 2003 11.  DCMA One Book Chapter 12.2, Small Business 12.  DCMA One Book Chapter 12.2.2, Comprehensive Subcontracting

Plan

Summary

Regardless of which type of Program Review, you must have:

-  Preparation -  Presentation -  Documentation -  Management Support -  Make the Closing

Questions??

Please Complete Seminar Evaluation