Public Law 95-507 requires that contracts over specified thresholds contain a subcontracting plan with goals. Reporting under those plans is being revised as part of implementation of Department of Justice's proposal to reform affirmative action in Federal procurement, which was designed to ensure compliance with the constitutional standards established by the Supreme Court.
The Electronic Contracting Reporting System (eSRS) is intended to streamline the small business subcontracting program reporting process and provide the data to agencies in a manner that will enable them to more effectively manage the program. Before the implementation of eSRS, the government did not really have an accurate count of the number of individual subcontracting plans and the number of Standard Form 295s being collected for individual subcontracting plans. With the electronic subcontracting reporting system, the government is now able to obtain a more accurate number. Although the number of subcontracting plans and individual subcontracting reports has significantly increased, the electronic system shortens the length of time for reporting the subcontracting achievements.
It is estimated that eSRS assists in reducing the time necessary to development a subcontracting plan to 7 hours and revises the time necessary for reporting/recordkeeping 2.0 hours. Total hours for Summary Subcontract Report are 9.0 hours. This is a reduction from the 12.4 hours for reporting into eSRS and development of the plan which results in a total of 1,161,081 hours, a reduction of 127,378 hours from the annual reporting burden published in the Federal Register at 75 FR 9603, on March 3, 2010 (1,288,459 hours).
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.