My company is bidding as a prime on a federal supplies set-aside, NAICS 332722, for parts for DLA through DIBBS. This is an RFQ and the deadline is next week. I'm trying to figure out how the limitations on subcontracting apply to this. I know there are rules about the percentage of work a prime must perform, but it seems to vary by contract type. For a supplies contract, does the prime need to manufacture the parts themselves, or does it refer to the cost of materials? What exactly counts as "the prime's work" for a supplies set-aside?
How do 'limitations on subcontracting' apply to a supplies set-aside contract?
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For a supplies set-aside, the prime contractor will not pay more than 50 percent of the amount paid by the Government, excluding the cost of materials, to subcontractors that are not similarly situated entities (FAR 52.219-14(e)(2)). This means that the prime's work is considered to be the value added to the materials, such as manufacturing, assembly, or other processing, rather than the raw cost of the components. The cost of materials is excluded from the calculation when determining the percentage of work performed by the prime versus subcontractors. Your company does not necessarily need to manufacture the parts themselves, but the value of the work performed on those parts, beyond just the material cost, must meet the 50 percent threshold.