VETS GWAC Subcontracting Report Instructions
All Industry Partners are required to enter subcontracting data semi-annually by individual task order in
the GWAC Management Module of ITSS (https://itss.gsa.gov). The reporting period runs from February
through July with reporting due August 31 and from August to January with reporting due by March 1 .
These reports are reviewed by the Small Business GWAC Center staff for compliance with FAR 52.219-
14, Limitations on Subcontracting. These reports are a mandatory requirement of the contract. An
industry partner’s failure to comply with this obligation will result in corrective action, i.e., performance
improvement plan, option not exercised, and possible termination of contract.
It is the Industry Partner’s responsibility to report in the GWAC MM at http://itss.gsa.gov.
Reporting period: February 1 to July 31 Report Due: August 31
August 1 to January 31 February 28 (or 29)
Prime contract holders may count work subcontracted out to other SDVOSB contractors as their own
work. Please refer to G.17 and G.24 of the contract, and also FAR 52.244-2. It is advisable to read the
subcontracting information shared with OCOs elsewhere in this guide. Subcontractor approval is not
required at the contract level.
Prime contractors are responsible for performing greater than 50% of the work at the contract level per
52.219-14, and should perform a meaningful amount on each order to prevent pass through situations
It is reasonable and routine that on larger tasks SDVOSB prime contractors may significantly rely upon
capacity building through subcontracting with other SDVOSB firms, or other than SDVOSB firms, to
provide scalability in the early stages of performance. It is reasonable to consider the total prospective life
cycle of an order, including options, when evaluating how much work the prime and SDVOSB
subcontractors, if any, plan to perform for a given task order. This life cycle perspective permits SDVOSB
primes to use their judgment in teaming to fulfill customer requirements, and to manage the expected
SDVOSB participation over the full span of an order.
For the applicable contract clauses, see your VETS GWAC contract or the Contract Library at
FAQs – Subcontract Reporting at ITSS.Gsa.Gov
1. I have no new task orders awarded on VETS GWAC contract; do I have to submit subcontracting
Yes. All subcontract information must be kept current.
Enter subcontracting information on each task order in the GWAC Management Module
(GWAC MM) in the “Small Business Subcontracting Data” section of each task. To
revise the data, use the “Edit” button.
2. I have no task orders. Do I have to report?
No, please report that information in your Quarterly Status Report
3. I have multiple subcontractors on a single task order, how do I reflect that on the report?
Enter each subcontract and their DUNS number in your task order at itss.gsa.gov in the
“Small Business Subcontracting Data” section of the "Order Package.”
Small Business Subcontracting Data
This section indicates the amount of work subcontracted under this particular order. This
information will be used to ensure that the amount of work subcontracted does not exceed
50% of the total amount of work completed pursuant to FAR 52.219-14 (Limitation on
Subcontracting). If work is subcontracted to a company that is exempt from the allowable
50% (applicable to the VETS GWAC only, please reference 13 CFR 125.6), you may
indicate this below. Only small business set-aside prime GWAC awardees are required to
complete this section.
One item found.
Company Name Exempt Subcontracte
Computed Total : $0.00
4. Can I fax or email the report back to you?
No, please report in the GWAC Management Module of ITSS
5. What is the correct reporting period for this report?
Please see the Ordering Guide.
6. The email address listed in the SBGWAC Center’s files is wrong. What do I need to do to change it?
The contract manager (who is currently of file – check the industry partner list of the
VETS GWAC website) or President/CEO must send an email to firstname.lastname@example.org or
an e-mail with an attached letter requesting the change.
7. What about 1099 employees?
1099 employees are considered subcontractors.
8. Where can I find further information regarding the VETS GWAC and the FAR 52.219-14, Limitations in
Go to www.gsa.gov/vetsgwac, Ordering Guide
Please contact the Small Business GWAC Center with any additional questions.
Small Business GWAC Center Toll-Free: (877) 327-8732