Diverse Suppliers Requirements

Many sponsors require that grantees make efforts to utilize small, minority-owned, and women-owned businesses whenever possible. In addition, recipients of sponsored awards must comply with applicable state, federal, sponsor, and university requirements for procuring goods and services when funds from these sources are used.

These requirements may include the need for sponsor approval prior to acquisition of goods or services.

All Federal Grants and Cooperative Agreements

OMB Circular A-110, Section 44(b) states:

"Positive efforts shall be made by recipients to utilize small businesses, minority-owned firms, and women's business enterprises, whenever possible. Recipients of Federal awards shall take all of the following steps to further this goal. 

  1. Ensure that small businesses, minority-owned firms, and women's business enterprises are used to the fullest extent practicable.
  2. Make information on forthcoming opportunities available and arrange time frames for purchases and contracts to encourage and facilitate participation by small businesses, minority-owned firms, and women's business enterprises.
  3. Consider in the contract process whether firms competing for larger contracts intend to subcontract with small businesses, minority-owned firms, and women's business enterprises.
  4. Encourage contracting with consortia of small businesses, minority-owned firms and women's business enterprises when a contract is too large for one of these firms to handle individually.
  5. Use the services and assistance, as appropriate, of such organizations as the Small Business Administration and the Department of Commerce's Minority Business Development Agency in the solicitation and utilization of small businesses, minority- owned firms and women's business enterprises."

New York State Contracts

New York State contracts that are over $1 million incorporate the Omnibus Procurement Act of 1992 whereby Cornell must state that it "has made reasonable efforts to encourage the participation of New York State Business Enterprises as suppliers and subcontractors, including certified minority and women-owned business enterprises, on this project, and has retained the documentation of these efforts to be provided upon request to the State."

Other New York State agencies, such as the Department of Environmental Conservation, have specific goals for Minority Owned Business Enterprise (MBE) and Women Owned Business Enterprise (WBE) participation.

Small Business Subcontracting Plan Process at Cornell

Unit research administrators are responsible for working with Cornell Procurement to create a Small Business Subcontracting Plan whenever required by an external sponsor. This guidance outlines the steps for requesting a Plan.

  1. Download the Subcontracting Plan Template here.
  2. Complete on page 1 of the Subcontracting Plan Template:
    • Date Solicitation Prepared
    • Solicitation Number
    • Contract (award) Number, if known
    • Period of Performance
    • Type of Plan, enter Individual
  3. Submit the completed draft Plan via email to ­procure.support@cornell.edu at least 7 business days before plan due date. Within the email, make sure to include the following:
    • A budget that includes a detailed breakdown of non-personnel direct costs (ex: materials and supplies, equipment, etc.) in Excel format. This budget should be the same as what was submitted to or will be submitted to the sponsor for award.
    • Identify a contact person from the administrative unit managing the project to whom Procurement will work with to answer any questions or concerns.

Please direct any questions regarding this process to procure.support@cornell.edu.

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