The University of Michigan must comply with federal reporting requirements by submitting periodic reports for contracts with small business subcontracting plans.
It is the responsibility of the research liaison to prepare and submit reports to the appropriate federal agency by the reporting deadlines:
|Report||Reporting Period||Due Date|
|Federal Semi-Annual (ISR)||Oct 1 – Mar 31||April 30|
|Federal Semi-Annual (ISR)||Apr 1 – Sept 30||Oct 30|
|Federal Annual (SSR)||Oct 1 – Sept 30||Oct 30|
In addition to submitting federal reports, the research liaison sends a quarterly Federal Small Business report for each contract to principal investigators (PI) and research administrators (RA) to keep them apprised of their progress toward meeting the small business goals.
|Reporting Period||Report sent to PI/RA|
|Oct 1 – Dec 31||Mid Jan|
|Jan 1 – Mar 31||Mid April*|
|Apr 1 – Jun 30||Mid July|
|Jul 1 – Sept 30||Mid Oct*|
*PI and/or RA certify spend is accurate for the reporting periods where submission to federal government is required
On a quarterly basis, the research liaison sends the Federal Small Business report to university departments. The report illustrates spend for the quarter as well as cumulative spend to date for each small business category.
It further breaks spend down by procurement method—PCard, PO/NonPO, and SUB—and allows departments to drill down to the transaction level. Each department is responsible for reviewing the quarterly report to ensure spend is accurately reflected and small business goals are being met.
If spend is accurate and goals are being met, certify the report is correct.
If discrepancies have been identified, contact the research liaison as soon as possible to adjust the report.
If goals are not being met, submit an explanation to research liaison and include the steps being taken to ensure goals will be met before the end of the contract.
Remember: Penalties may be imposed by the sponsor for not meeting the small business subcontracting goals.
Once the department confirms the spend is accurate, the research liaison is responsible for submitting semiannual and annual reports to the appropriate federal agency with the cumulative spend in each small business and large-business category for the contract.
If goals are not being met, the semi-annual report submitted to the sponsor must include a reason for non-achievement of goals and the steps being taken to meet the goals before the end of the contract.
The research liaison will be notified if the report was accepted or rejected by the sponsor. If the report is rejected, the research liaison may need to request additional information and/or explanation from the department.
Every three years, or as needed, the federal government’s Office of Naval Research conducts a Contractor Purchasing System Review (CPSR) of the university’s procurement system, policies, and procedures. The CPSR evaluates the efficiency and effectiveness with which the university spends federal funds and complies with federal policies when subcontracting to suppliers or other institutions.
Part of the CPSR focuses on the university’s small business subcontracting program. When the principal investigator (PI) signs the small business plan required by a contract, they are agreeing to meet the small business subcontracting goals specified in the plan. Compliance with this federal requirement is required.