FAR 19.704 Subcontracting Plans: What to Ask the Prime GC
When trade contractors bid on federal construction projects, prime contractors are frequently required to carry an approved small business subcontracting plan. Understanding the statutory elements outlined in FAR 19.704 Subcontracting plan requirements gives interior, framing, and drywall estimators a distinct advantage when approaching a general contractor. By framing your pitch around the exact compliance requirements the prime must satisfy, you can position your firm as an active solution to their federal obligations. Here are the specific questions trade contractors should ask a prime contractor before bid day.
1. Which Specific Socioeconomic Categories Are You Targeting on This Job?
Under FAR 19.704(a)(1), every required subcontracting plan must include separate percentage goals for utilizing different socioeconomic groups. Subcontractors should ask the GC which categories they still need to fulfill. The designated categories include:
- Small business concerns (including Alaska Native Corporations [ANCs] and Indian tribes)
- Veteran-owned small business concerns
- Service-disabled veteran-owned small business concerns
- HUBZone small business concerns
- Small disadvantaged business concerns (including ANCs and Indian tribes)
- Women-owned small business concerns
A prime's plan must state total planned subcontract dollars and break down the percentages allocated to each group. On individual subcontracting plans, a contracting officer may also require these goals to be calculated as a percentage of total contract dollars. Asking where the prime faces a deficit helps you emphasize your certifications immediately.
2. Are Interior Scopes Explicitly Listed in Your Plan's Supplies and Services?
FAR 19.704(a)(3) mandates that the prime contractor describe the principal types of supplies and services planned to be subcontracted, specifically identifying which items will go to small business categories. When presenting your proposal during bid day preparation, ask the GC's estimating team whether metal stud framing, drywall, insulation, or acoustical ceilings are identified as small business subcontracting targets. If those scopes are already earmarked, the prime has an explicit regulatory incentive to award that package to a qualifying small trade contractor rather than self-performing or using a large firm.
3. Will You Formally Name Our Firm or Use Written Evidence of Intent?
FAR 19.704(a)(12) provides a vital protection that trade estimators should raise during pre-bid negotiations. The prime must make a good faith effort to acquire construction work, supplies, or services from the small businesses it used in preparing its proposal, matching the same or greater scope, amount, and quality. However, the regulation specifies that merely responding to a request for a quote does not mean the prime "used" your business.
To ensure protection under this rule, ask the GC if they will either:
- Identify your firm by name as a subcontractor in their bid, proposal, or associated small business subcontracting plan, or
- Use your pricing, cost data, or technical expertise with written evidence showing an intent or understanding that you will receive the award if they win the prime contract.
If the prime uses your firm under those terms and fails to award the work, FAR 19.704(a)(13) requires them to submit a written explanation directly to the federal contracting officer within 30 days of contract completion.
4. Who Is the Designated Individual Administering Your Subcontracting Program?
Under FAR 19.704(a)(7), a subcontracting plan must include the name and operational duties of an employee who administers the contractor's program. When marketing your firm, ask the project team for the direct contact information of this program administrator. Because this individual is evaluated on identifying potential sources under FAR 19.704(a)(5) and maintaining internal source lists under FAR 19.704(a)(11), contacting them directly ensures your firm gets added to solicitations across multiple bids.
5. What Are the Jobsite Payment Terms and Dialogue Rules?
Subcontractors should verify how the prime handles contract cash flow. Under FAR 19.704(a)(15), the prime must give assurances that it will pay small business subcontractors on time in accordance with subcontract terms and must notify the contracting officer if it makes a reduced or untimely payment under FAR 52.242-5. For more on cash flow protections, review our guide to prompt payment for subcontractors. Furthermore, under FAR 19.704(a)(14), the prime cannot forbid your firm from speaking directly with the contracting officer about payment issues or subcontractor utilization matters.
6. Does Our Package Cross the Threshold for a Lower-Tier Subcontracting Plan?
If your subcontract is substantial, lower-tier flow-down rules may apply. Under FAR 19.704(a)(9), the prime contractor must include FAR 52.219-8 in subcontracts that provide further opportunities. Furthermore, any subcontractor that is not a small business must adopt its own subcontracting plan under FAR 52.219-9 if its subcontract exceeds $900,000, or $2 million for construction contracts. If you operate as a mid-sized tier contractor partnering with specialized trade crews, ask the GC to confirm whether your contract value triggers these reporting duties.
Sources
FAR 19.704 Subcontracting plan requirements. | Acquisition.GOV
Published October 30, 2026. No affiliate links on this page. Facts come from the sources linked above; check them for updates.