Office of Contract Compliance
University of Cincinnati
PO Box 210267
Cincinnati OH 45221-0167
Phone
Fax
(513) 556-1922
(513) 556-0097
MASTER SUBCONTRACTING PLAN
The following, together with the attachment, is submitted as a Subcontracting
Plan to satisfy the applicable requirements of Public Law 95-507, 103-355, 105-135 and
106-50 as implemented by the Federal Acquisition Regulation, the Defense Supplement
thereto, Public Law 100-180 and 103-337.
1. Goals:
Individual Small Business Program goals will be established for each
solicitation/contract. The goals will include percentages, dollars and a description of
products and/or services to be obtained from the following small business concerns;
small, veteran-owned (VOSB), service-disabled veteran-owned (SDVO), historically
underutilized business zone (HUBZone), small disadvantaged (SDB), and womenowned (WOSB) as indicated by Attachment (A).
2. Method Used To Develop Goals:
The University of Cincinnati's commitment mandates that vendors holding
University contracts, or purchase orders, adhere to the same equal employment
opportunity practices as the University in respect to their own employees and
subcontractors.
As a recipient of Federal, State and local funds, the University of Cincinnati is
required to comply with the following, in addition to the above federal procurement
requirements:
 Sections 153.59 and 153.591 of the Ohio Revised Code “Discrimination
and intimidation on account of race, religion, sex, disability, national origin
or ancestry”
 January 27, 1972 Executive Order of the Governor of the State of Ohio
regarding requirements of Equal Employment Opportunity.
 Section 123.151 of the Ohio Revised Code “Percentage of contracts to be
set aside for minority business enterprises; minority participation in other
contracts; misrepresentation prohibited”
 Section 3345.29 of the Ohio Revised Code “Contract compliance office
established”
 University Board Rule 10-13-01 Affirmative action: University policy
statement.
An affirmative action/equal opportunity institution
Pursuant to current State of Ohio law, the University of Cincinnati’s goal is to set
aside 15% of the goods and services bids for competition by state certified Minority
Business Enterprises. Minority vendors must be certified by the Department of
Administrative Services, Equal Opportunity Division, prior to participation. The Director
of the Office of Contract Compliance is responsible for the appropriate registration
designation of vendors. Updated reports are obtained from the Department of
Administrative Services Equal Opportunity Division.
Federal and/or State grants held by University Departments, in whatever dollar
amount, are subject to review as part of the University's overall dollar receipt of Federal
and/or State grant moneys.
3. Method Used to Identify Potential Sources:
Source lists utilized in developing the goals for individual contracts include:
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The South Central Ohio Regional Minority Purchasing Council within the
Greater Cincinnati Chamber of Commerce. http://www.scombc.org
The Cincinnati Minority Business Assistance Corporation.
The Ohio Statewide Minority Business Development Center
The Cincinnati branch office of the U.S. Small Business Administration
U.S. Small Business Administration data base (PRO-Net) http://pronet.sba.gov
Minority Business Development Corporation (National)
Allied Construction Industries of Cincinnati.
Women Entrepreneurs, Inc.
Ohio Department of Development, Division of Minority Business Affairs webbased MBE Qualified Service Providers
http://www.state.oh.us/das/eod/MBESearch/index.asp
4. Indirect Costs:
Indirect and overhead cost ____ have __X__ have not been included in the goals
described in the attachment.
Indirect Costs: The University of Cincinnati to date has no experience in accumulating
data specifically identifying indirect cost procurements to an individual subcontract. The
existing hypothesis is procurement of goods and services made which are included in
the indirect cost allocation will have the same ratio as procurement of goods and
services in the direct costs.
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5. Subcontract Plan Administrator
Name:
Title:
Address:
Telephone No:
E-Mail Address:
Cheryl A. Smith
Director, Contract Compliance, University of Cincinnati
University Hall, Room 320, Cincinnati, Ohio 45221-0167
513-556-2366
Fax No: 513-556-0097
Cheryl.Smith@UC.Edu
Specific duties of the subcontract plan administrator are:

Develop and maintain bidder’s lists of SB, SDVO, VOSB, HUBZone SB, SDB,
and WOSB concerns from all possible sources.
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Ensure that procurement packages are structured to permit SB, SDVO,
VOSB, HUBZone SB, SDB, and WOSB concerns to participate to the
maximum extent possible.

Assure inclusion of SB, SDVO, VOSB, HUBZone SB, SDB and WOSB
concerns in all solicitations for products or services which they are capable of
providing.
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Ensure periodic rotation of potential subcontractors on bidders lists.
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Ensure that the proposal review board documents its reason for not selecting
lowest priced proposals submitted by SB, SDVO, VOSB, HUBZone SB, SDB,
and WOSB concerns.
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Conduct or arrange for conduct of motivational training for purchasing
personnel pursuant to the intent of P.L. 95-507.
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Coordinate the conduct of University of Cincinnati’s activities involving its
small and small disadvantaged business subcontracting program.
Additions to the duties specified above are as follows:

The University of Cincinnati academic department submitting the individual
subcontracting plan is responsible for establishing and maintaining records of
solicitation and subcontract award activity, monitoring attainment of proposed
goals and preparation of periodic subcontracting reports.

The University of Cincinnati Purchasing Department is responsible for
procurement of goods and services for the entire University, including the
Clifton Campus, the Medical Center, OMI College of Applied Science,
Raymond Walters College, and Clermont College.

The Purchasing Department is responsible for monitoring all purchases of
goods and services from certified minority vendors. Buyers are required to
designate all bids over fifteen thousand dollars as Set Aside whenever they
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can identify an MBE vendor certified by the State of Ohio. Compliance of
each Buyer is audited quarterly.

The Office of Contract Compliance, University of Cincinnati (OCCUC) is
responsible for maintaining vendor contract compliance by monitoring and
making initial and continuous reviews of those holding or seeking University
contracts or commissions over the sum of $4,000, and purchase orders over
$2,000. OCCUC works closely with the Purchasing Department and is
responsible for monitoring the affirmative action posture of all vendors.
6. Equitable Opportunity:
The following efforts will be taken to assure that SB, SDVO, VOSB, HUBZone
SB, SDB, to include HBCU/MIs, and WOSB concerns will have an equitable opportunity
to compete for subcontracts.
Outreach efforts will include:
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Contacts with minority and small business trade associations.
Contacts with business development organizations.
Attendance at small and minority business procurement conferences
The Office of Contract Compliance also plays a major role in recruiting minority
vendors, suppliers, and contractors to enhance minority entrepreneurs’ access to
business opportunities at the University of Cincinnati.
The University of Cincinnati:
 Is an active participant in the South Central Ohio Minority Business Council
 Attends buyer/seller meetings, hosted the State and Regional annual
meetings of the Minority Business Development Center.
 Provides lists of our bid opportunities to the Greater Cincinnati African
American Chamber of Commerce.
 Advertises in the Cincinnati Herald which provides news, sports and
commentary from an African-American perspective.
 Gives presentations frequently to MBE meetings on doing business with the
University.
 Publishes a “Minority Supplier Guide”.
The University of Cincinnati Purchasing Department and Office of Contract
Compliance website contains policy, procedure and contact information for any vendor
interested in working with the University. http://www.uc.edu/af/purchasing
A focal point of the University minority Business Enterprise Development
program is its participation in the state set-aside program. Major price inquiries are
placed for set-aside bidding when one or more state-certified, minority firms are
available in our service region.
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In accordance with Ohio Revised Code 125.081, first consideration is given to
any qualified set-aside response that is competitive before any consideration is given to
the open market offers. Minority firms who are not yet state certified or who are not
based in the State of Ohio can register with the University for inclusion as a bidder on
regular open market bidding.
a. The University will award subcontracts and purchase orders to small business
concerns in all circumstances where this can be done consistent with the
efficient performance of the contract and at equitable prices for the Industry.
b. Sources will be identified from:
 SBA PRO-Net System (www.sba.gov)
 Ohio Department of Development, Division of Minority Business Affairs
web-based MBE Qualified Service Providers
http://www.state.oh.us/das/eod/MBESearch/index.asp
 The South Central Ohio Regional Minority Purchasing Council within
the Greater Cincinnati Chamber of Commerce. http://www.scombc.org
c. The following internal efforts will be made to guide and encourage buyers:
(List all that apply)
(1)
(2)
Workshops, seminars, and training programs will be conducted.
Arrange interviews with SB/ SDVO/VOSB/ HUBZone
SB/SDB/WOSB concerns and HBCU/MIs.
The University of Cincinnati, through the Office of Contract Compliance,
provides resources and actively participates with external organizations
such as the South Central Ohio Minority Business Center (SCOMBC) and
the Cincinnati Minority Contract and Business Assistance Council
(CMCBAC). Staff and the above agencies assist minority vendors with
procedural/buyer relationships necessary for successful business efforts.
This is done by evaluating the capabilities of vendors to make certain that
they can, in fact, handle projects that are awarded, and by updating
vendor registrations.
The Purchasing Department staff provides assistance to vendors for
developing affirmative action plans, minority hiring plans and interpretation
of the affected rules and regulations of the university.
d. Describe extent to which offeror (University of Cincinnati) plans to restrict
competition to Historically Black Colleges & Universities/Minority Institutions.
When appropriate to the needs of the University of Cincinnati, Historically
Black Colleges & Universities and other Minority Institutions will be and
have been utilized.
7. Flow-down of Clauses:
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The University of Cincinnati agrees that Federal Acquisition Regulation clause
52.219-8 entitled "Utilization of Small Business Concerns will be included in all
subcontracts which offer further subcontracting opportunities, and all subcontractors,
except SB concerns, who receive subcontracts in excess of $500,000 will be required to
adopt and comply with a subcontracting plan similar to the plan required by Federal
Acquisition Regulation 52.219-9, entitled "Small, Business Subcontracting Plan. Such
plans will be reviewed by comparing them with the provisions of P.L. 95-507 and
assuring that all minimum requirements of an acceptable subcontracting plan have been
satisfied. The acceptability of percentage goals shall be determined on a case-by-case
basis depending on the supplies/services involved, the availability of potential small,
veteran-owned small business, service disabled veteran-owned, HUBZone small, small
disadvantaged and women-owned small business subcontractors, and prior experience.
Once approved and implemented, plans will be monitored through the submission of
periodic reports.
8. Reports and Surveys:
The University of Cincinnati agrees to submit such periodic reports and
cooperate in any studies or surveys as may be required by the contracting agency or
the Small Business Administration in order to determine the extent of compliance by the
University of Cincinnati with the subcontracting plan and with the clause entitled
“Utilization of Small Business Concerns” contained in the applicable contract.
The University of Cincinnati agrees to submit the original and copy of
"Subcontracting Report for Individual Contracts, standard form (SF) 294, in accordance
with the instructions on the report as referenced in P.L. 95-507, Section 211.
Regardless of the effective date of this contract, the report will be submitted for the
entire life of the contract within thirty (30) days after the close of each reporting period.
The report will be sent to the designated contracting office with a copy to the cognizant
SBA commercial marketing representative.
The University of Cincinnati agrees to submit the "Summary Subcontract Report",
SF 295, in accordance with the instructions on the report as referenced in P.L. 95-507,
Section 211. The Summary Report of DOD awards will be submitted within thirty (30)
days after the close of each reporting period to the Administrating Contracting Officer
with a copy to the cognizant SBA commercial marketing representative.
The University will maintain and provide the appropriate federal agency records
to be completed by each Project Director or Principal / Co-Principal Investigator that
indicates:
(1)
(2)
(3)
Whether each prospective subcontractor is a small business concern,
women-owned, or a small disadvantaged business concern
Procedures which have been adopted to comply with this plan and
With respect to the letting of any contract or purchase order exceeding
$500,000, information:
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a)
Whether the award went to a Large Business, Small Business,
Women-owned Small Business, Small Disadvantaged Business
(including Historically Black Colleges and Universities / Minority
Institutions) , Veteran-owned Small Business, Service Disabled
Veteran-owned Small Business and/or HUBZone Small Business.
b)
The reason for failure of these affected business concerns to
receive the award if such was the case when such firms were
solicited.
The records maintained in accordance with (3) above shall be summarized
biannually and submitted to the Director of Contract Compliance, University of
Cincinnati. This information will be submitted on the Summary Subcontracting Report,
Standard Form (SF) 295 and Subcontracting Report for Individual Contracts, SF 294 in
accordance with instructions on the forms.
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9. Maintenance of Records:
The University of Cincinnati agrees that it will maintain at least the following types
of records to document compliance with this subcontracting plan.
a.
Source list, guides, and other data identifying SB, SDVO, VOSB,
HUBZone SB, SDB, and WOSB concerns.
b.
Organizations contacted to locate SB, SDVO, VOSB, HUBZone SB, SDB,
and WOSB concerns.
Signed: ___________________________________________________________
Date_____________________________
Name:
Title:
Cheryl A. Smith
Director, Office of Contract Compliance
University of Cincinnati
Approved by:
____________________________________Date
Administering Contracting Officer
Name:
Organization:
Address:
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