Small business participation plan vs subcontracting plan: what is the difference when the RFP asks for both?

A small business subcontracting plan is required for other-than-small businesses on solicitations that exceed $900,000 and have subcontracting possibilities, while a small business participation plan is an evaluation factor that demonstrates a prime contractor's commitment to using small businesses in contract performance.

Yes, small businesses you use as subcontractors generally count towards both the subcontracting plan and the small business participation evaluation. The subcontracting plan, required by FAR 19.702(a)(1), outlines specific goals for subcontracting with various small business categories. The participation plan, however, shows how you plan to integrate small businesses into the overall contract effort, which can include more than just direct subcontracting dollars. A small business prime contractor does not have to submit a small business subcontracting plan, but they may still need to address small business participation if it is an evaluation factor. Evaluators typically score small business participation based on the offeror's detailed plan, the percentage of work proposed for small businesses, and the prime's past performance in utilizing small businesses.