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Transcript of Page Federal Contracting Self-Certification Compliance Using Your ERP System May 9, 2013 Midwest...
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Federal Contracting
Self-Certification Compliance Using Your ERP System
May 9, 2013
Midwest SBLO Group
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Self-Certification Requirements
Presented by
Ray Suennen
Governmental Contracts
Compliance Coordinator
Integrys Energy Services, Inc
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Self-Certification Requirements
eSRS Instructions
Quick reference # 3
you must have a supporting written size self-certification for every small business you are counting in the small business and socioeconomic section of this report at the time you submit your proposal
Per 13 (CFR) 121.404 (e) & 121.410
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Self-Certification Requirements
eSRS Instructions
Quick reference # 3
a subcontractor must qualify and self-certify as a small business at the time it submits its offer as a small business subcontractor.
Per 13 CFR 121.411(a)
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Self-Certification Requirements
Representations & Certifications FAR 4.1201 (b)(1)
Prospective contractors shall update the representations and certifications submitted to ORCA as necessary, but at least annually; to ensure they are kept current, accurate, and complete.
The representations and certifications are effective until one year from date of submission or update to ORCA.
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Self-Certification Requirements
Small Business Subcontracting Plan
The achievement of the goals of a small business subcontracting plan are measured by the percent of a Contractor’s subcontracting Spend with socioeconomic business concerns
The validity of the Spend percents, is based upon the supporting representations and certifications, which are primarily received directly from the subcontractors
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Self-Certification Requirements
The following process was developed for a commercial Subcontracting Plan.
The process can also be used for an individual plan by adding project numbers.
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What “Tools” do you need to use existing systems?
Maintaining self-certifications can be
done in-house, it will involve;
System enhancements (not complex)
IT Programmer
Your “Time”
Understanding of FAR requirements
Leaderships willingness to modify systems
Business case8
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What “Tools” do you need to use existing systems?
Maintaining self-certifications can be
done in-house, it will involve;
Business case (reasons why –
Compliance with FAR
Control of data
Accessibility (ease and timing)
Cost – ongoing is limited
Security – no external parties involved
Confidentiality of Company data
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What “Tools” do you need to use existing systems?
Summary of what it takes;
One-Time Set Ups
Add fields to store data in the system
Create reports to pull the data from the system
Annual Updates
Mailing self-certification classification request forms
Updating the purchasing system from the returned self-certification forms
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What “Tools” do you need to use existing systems?
Systems involved
Purchasing system
– has vendor information
Accounts payable system
– has dollars spend by vendor
General ledger
– has total company spend
(note - PeopleSoft ERP system is used)11
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What “Tools” do you need to use existing systems?
Purchasing System
Already contains individual vendor records
Vendor name
Vendor address
Vendor number (primary key field)
Vendor “type” (VIP field)
DUNS number (may not be used)
This information is used for the mailing of the
“Request to Update Self-Certification Form”
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What “Tools” do you need to use existing systems?
Purchasing System
The vendor “Type” field
Allows for users to set up desired identifiers
(existing functionality)
One vendor can have multiple vendor types
May have a limited number of characters (3)
Need a group of codes that you “own”
Everything that starts with a “Y” and “Z”
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What “Tools” do you need to use existing systems?
Purchasing System
Vendor “type” field
Create and set up vendor codes; ZDB – Small Disadvantaged Bus
ZHZ – HubZone Business
ZDV – Disabled Veterans
(service-disabled V/O S/B)
ZVO – Veteran Owned S/B
ZWO - Women Owned S/B
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What “Tools” do you need to use existing systems?
Purchasing System
Vendor “type” field
Create and set up vendor codes;
Z8A – Business Development
ZBC – Black Colleges & Universities
ZMI – Minority Institutions
ZFO – Foreign Owned
ZFQ – Foreign Qualified
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What “Tools” do you need to use existing systems?
Purchasing System
Vendor “type” field
Create and set up vendor codes;
ZLT – Long-Term Contracts
For Supplier Diversity reporting
YMO – Minority Owned Large Bus.
YMO – Women Owned Large Bus.
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What “Tools” do you need to use existing systems?
Purchasing System
Vendor “type” field
Create and set up vendor codes;
ZLB – Large Business
ZEE – Employee Expenses
ZIC – Inter-company payment
(affiliated companies)
ZCU – Customer refunds etc17
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What “Tools” do you need to use existing systems?
Purchasing System
is the only system needing enchancements
Need to add “Fields” to the tables
Self-certification “Classification Date”
Long-Term Contract Start Date
Long-Term Contract End Date
Certification Ending Date
(8A & HUBZone)
NAICS Code
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What “Tools” do you need to use existing systems?
IT Programmer
Needs to create reports to retrieve the data
Self-certifications Classification Update form
Size Spend Report
Type Spend Report
Expired Classifications Report
Subcontracting Income Statement Report
Create online viewing capabilities screen of vendor accounts
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Reports
Self-certifications Classification Update Form
Creates a form to be mailed to the vendor
Criteria - must have Spend within the current year – from accounts payable
sys.
(you input the desired to/from dates)
Retrieves from the purchasing system the existing classification codes, last date
update, NAICS code, DUNS #, name and address (it is ready for mailing)
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Reports
Self-certifications Classification Update form
The returned form contains the
Signature of the authorized person
Date signed (new classification date)
Updated classification codes
Additional information may include
DUNS, NAICS, product description 21
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Reports
Self-certifications Classification Update form
Forms are not sent to
Large Businesses
Customers
Employees
Affiliated companies
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ReportseportsSize Spend Report (used for reviewing purposes)
Retrieves by the First Tier Hierarchy
ZSB – with current classification dates
ZSB – with expired classification dates
ZLB – all large business spend
ZIC – Affiliated company spend
ZEE – Employee spend
blank – All companies without
classification codes(Excel Spreadsheet)
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Reports
Type Spend Report (Excel Spreadsheet)
This report provides the
Socioeconomic Spend amounts for the eSRS Small Business
Subcontracting Report
SDB Spend for the Year-End Supplemental Report for Small Disadvantaged Businesses
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Reports
Type Spend Report (Excel Spreadsheet)
Retrieves Spend (input to/from Spend dates)
Vendor name
Vendor number
NAICS code
Spend by classification code;
Small Business not preferential
Z8A – Business Development
Black Colleges & Universities
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Reports
Type Spend Report (Excel Spreadsheet)
Retrieves Spend
Spend by classification code;
Minority Institutions
Small Disadvantaged Business
HUBZone business concerns
Service Disabled Veteran S/B
Veteran Owned S/B
Women Owned S/B
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Reports
Type Spend Report (Excel Spreadsheet)
The report totals the
Preferential Spend categories
(includes multiple spend credits)
Multiple counted Spend Credits
The difference is the actual Spend (only counted once) which equals the Spend on the Size Spend Report
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Reports
Subcontracting Income Statement Report
This report provides the
Total Revenue and the
Total Subcontracting Spend for the
Subcontracting Reports (eSRS)
Subcontracting Plans
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Reports
Subcontracting Income Statement Report
Retrieves from the accounting system
(for the to/from period input)
An income statement
Net change in the
Fixed assets
Inventory
May be other asset accounts
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Reports
Subcontracting Income Statement Report
The report
Adds back - discontinued operations
Subtracts;
Intercompany expenses
Non-cash items (depreciation, amort.)Non-subcontractable items
(employee)
= Total Subcontracting Spend
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Reports
Expired Classifications Report
Provides a list of vendors that have no
- classification codes or
- outdated socioeconomic classification codes
Identifies Spend (input to/from period)
Can be ran at any time
Is used to identity which vendors to follow up on, especially if Spend is significant
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What “Tools” do you need to use existing systems?
Your “Time”
There are trade offs here
Invest time to set up (up front)
Information almost immediately available
You control all of the data
You control when you pull the data
No external party has access to your system information (big issue with our company – security and confidentiality)
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Self-Certification Compliance Using Your ERP System
Summary
The process
Is easy to use
Is totally in your control
Is available to use at any time
Has checks and balances
Provides solid verifiable documentation
Easy access to outdated Classifications
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Self-Certification Compliance Using Your ERP System
Summary
The process
If updated every 12 months, is current Meets the criteria of accurate and
complete Meets the requirement of - you must have a supporting written self-certification
Personal opinion; I feel that in the long-term, it provides cost savings
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Summary
What are your
questions
and
comments?
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