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Tier Levels & Requirements
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Tier E: Emerging Subcontractor
Purpose: Provide a proven pathway for newer firms to build readiness and move into Tier-1.
Requirements:
- Registered in SAM.gov and active Unique Entity ID (UEI)
- Verified legal entity (U.S.-based), verifiable address, key management contacts
- At least one (1) completed assignment or contract (could be non-federal) in last 24 months
- Submission of basic company profile, NAICS codes, preliminary capabilities statement
- Agreement to abide by FCCoC Subcontractor Registry Code of Conduct and data-sharing obligations
Advantages:
- Entry listing in directory under “Emerging – FCCoC”
- Access to FCCoC foundational training modules (intro to federal subcontracting)
- Eligibility to receive “Emerging NOI” (Notice of Intent) alerts for opportunities up to $100,000
Accountability/Monitoring:
- Subcontractor must submit annual self-certification/attestation of continuing readiness
- FCCoC reserves the right to review basic compliance records, and may require upgrade or removal if no activity in 12 months
FEE- $1500.00 - ANNUALLY
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Tier 1: Registered Subcontractor
Requirements:
- All Emerging level requirements (or, if not using Emerging, the prior “Tier 1” baseline)
- Active SAM.gov registration, valid UEI, no active suspension/debarment
- Fully completed FCCoC Subcontractor Readiness Program (or approved equivalent) and passed a readiness assessment/test (minimum score X%)
- Upload of full capabilities statement and profile, identified NAICS codes, DUNS/UEI etc.
- Verifiable basic past performance: at least one subcontract or contract in last 18 months (could be small)
- Willingness to submit subcontracting performance data (e.g., % of small business spend, timely delivery, change-order history) via FCCoC annual questionnaire
- Signed Subcontractor Registry Participation Agreement including clause to allow FCCoC to verify past performance and to remove rating for cause.
Advantages:
- Standard listing in FCCoC Subcontractor Directory (with “Tier 1” badge)
- Access to FCCoC “Tier 1-only” notices of intention for opportunities up to $150,000-$250,000
- Access to FCCoC training modules (compliance, teaming, proposal basics)
Accountability/Monitoring:
- Annual renewal required: submission of updated capabilities, verification of active registrations, disclosure of any new suspensions/debarments
- Semi-annual performance self-report: attestation of continuing activity, changes in ownership/management, any contract issues
- Right of FCCoC to audit a random sample of Tier 1 firms each year (e.g., 5-10% sample) for documentation and accuracy
- If the subcontractor fails to respond, or misrepresents data, FCCoC may downgrade them to Emerging or remove them from the registry
FEE- $3000.00 - ANNUALLY
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Tier 2: Certified Contract-Ready Subcontractor
Requirements:
- All Tier 1 requirements PLUS:
- Minimum of 3 verified past performance references in the last 3 years (contracts or subcontracts) with documented client evaluations
- Valid small business status (for example, via SBA: 8(a), WOSB, HUBZone, VOSB, or other) or equivalent certification
- Completed FCCoC “Contract-Ready” training modules (including proposal teaming, subcontractor management, subcontract compliance) and passed corresponding assessment (score minimum Y%)
- Active participation (as member or speaker) in at least one FCCoC industry committee or working group (e.g., GSA, DoD, VA, small business outreach) in last 12 months
- Submission of key performance indicators (KPIs) for last 2 years (e.g., number of contracts awarded, dollar value, % on-time delivery, change-order rate, small‐business participation rate, subcontractor turnover, quality/defect issues)
- Agreement to quarterly reporting to FCCoC (or as required) of major contract milestones/metrics
Advantages:
- “Tier 2 – Certified Contract-Ready” badge and priority placement in directory search results
- Eligibility for FCCoC “Tier 2-only” NOI alerts for opportunities up to $250,000- $500,000
- Highlighted profile in matchmaking, teaming events, and prime-offeror referral lists
- Access to advanced business development support, template libraries, joint-venture matchmaking
Accountability/Monitoring:
- Annual renewal with full KPI submission for previous year, verification of small-business certification, verification of past performance references
- Quarterly self-reporting of key metrics and any material changes (ownership, management, financial status, compliance events)
- Twice yearly random audit/review by FCCoC (or its designated oversight committee) of supporting docs for performance claims
- If any major negative event occurs (e.g., suspension/debarment, major contract failure, poor performance rating from prime), subcontractor may be downgraded to Tier 1 or removed entirely
- Subcontractor must maintain an improvement plan if KPI thresholds fall below defined benchmarks (see below)
FEE- $4000.00 - ANNUALLY
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Tier 3: Elite Performance Subcontractor
Requirements:
- All Tier 2 requirements PLUS:
- At least two or more full federal contracts or subcontracts completed in last 3 years (or equivalent major projects) with exceptional performance evaluations (client references reflecting excellent delivery, schedule/quality adherence)
- Demonstrated compliance discipline: e.g., zero unresolved audit findings, internal quality/compliance program, documented risk management procedures
- Completion of FCCoC “Advanced Contracting Excellence” modules (pricing strategy, audit readiness, subcontract-compliance management, supplier diversity optimization) and passed assessments (score minimum Z%)
- Letter(s) of recommendation from a prime contractor, government agency, or FCCoC partner attesting to high performance, teaming leadership and reliability
- Active leadership role in FCCoC: for example, speaking at events, mentoring other subcontractors, sponsoring an initiative or serving on the steering committee
- Submission of rigorous KPI set for last 3 years (e.g., contractor satisfaction scores, % over target, change-order frequency, cost growth, schedule variance, small business participation exceeded goal, TEAMS created)
- Commitment to “bench-marked continuous improvement”: subcontractor shall set and publish annual improvement targets (e.g., reduce schedule variance by X%, increase small-business teaming by Y%)
Advantages:
- “Tier 3 – Elite” badge and distinctive highlighting in FCCoC directory, marketing materials and prime contractor/agency referral lists
- Eligibility for FCCoC “Tier 3-only” NOI alerts for subcontracting up to $500, 000 to $1 million
- Invitation to high-visibility procurement roundtables, policy discussions, prime-subcontractor networking forums
- Access to premium templates, direct legal/compliance advisory referrals, and marketing co-promotion by FCCoC
Accountability/Monitoring:
- Annual renewal process including full KPI submission, verification of performance references, review of improvement targets and achievement
- Quarterly self-reporting of KPIs and any major shifts (financial, management, contracts)
- Annual independent audit or peer review of subcontractor performance claims and compliance (FCCoC may contract an external reviewer)
- If subcontractor falls below defined benchmark thresholds or incurs major negative event (e.g., suspension/debarment, termination for default, significant cost/schedule overrun) FCCoC may suspend or remove Tier 3 status or revert to Tier 2. Subcontractor must submit and implement a Corrective Action Plan (CAP) to regain elite status.
- Practicum: If a Tier 3 subcontractor fails two years in a row to meet improvement targets or lapses performance, they are automatically reviewed for removal from elite listing.
FEE- $5000.00 - ANNUALLY
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KPI Framework & Benchmarks
To make this program truly Fortune 500-style, we must embed measurable performance metrics and benchmark thresholds. Subcontractors are to report metrics and FCCoC may create dashboard views, aggregate benchmarking, “scorecards” and trend-analysis similar to how big corporations manage vendor performance.
Suggested KPI categories (minimum data):
- Number of subcontract awards in the last 12 months
- Total dollar value of subcontract awards
- Percentage of subcontract awards by size (e.g., <$250k, $250k-$1m, >$1m)
- On-time delivery rate (% of subcontract tasks/milestones met on schedule)
- Change-order frequency (% of tasks requiring change-orders)
- Cost growth (% increase from original subcontract value)
- Customer satisfaction / Past performance rating (e.g., prime contractor evaluation score)
- Small-business teaming score (% spend to small/diverse firms)
- Compliance issues (# of audit findings, # of DCAA/DCMA issues)
- Turnover of key personnel (% within last 12 months)
- Improvement target achievement (vs. prior year)
Benchmarks (examples):
- On-time delivery ≥ 90% for Tier 2; ≥ 95% for Tier 3
- Change-order rate ≤ 10% for Tier 2; ≤ 5% for Tier 3
- Cost growth ≤ 5% for Tier 3
- Customer satisfaction rating ≥ 4.5/5 for Tier 3
- Small business teaming spend ≥ 30% (or defined goal) for Tier 2; ≥ 40% for Tier 3
- Zero active audit findings for Tier 3
FCCoC will annually review aggregate data and update benchmark thresholds to remain current with industry-best performance.
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Governance, Audit & Continuous Improvement
- Create an FCCoC Subcontractor Rating Oversight Committee (analogous to a Fortune 500 vendor management steering committee) – composed of FCCoC leadership, prime contractor members, federal agency partners, subject‐matter experts. Their responsibilities: review program performance, oversight of audits, approve tiers and criteria updates annually.
- FCCoC to publish (internally or publicly) an annual “Subcontractor Registry Performance Report” – summarizing number of firms in each tier, renewal/attrition rates, average metrics, performance trends, and any removals/suspensions.
- Audits: Each tier has a defined audit frequency (random sampling for Tier 1, higher frequency for Tier 2, full annual for Tier 3). Audits verify documentation, authenticity of performance claims, compliance with registration terms.
- Corrective Action Plans (CAPs): If a subcontractor fails to meet required performance or misrepresents status, they will be required to submit CAP within 30 days. CAP must include root‐cause analysis, action items, milestone dates, owner, and progress reporting. Failure to implement CAP may result in downgrade or removal.
- Renewal & Re-rating: Every firm must renew annually (more frequent for higher tiers if needed) and their tier status is subject to reaffirmation of requirements plus review of latest metrics. Upgrades possible when higher tier criteria met; downgrades or removals when criteria not met.
- Transparency & Visibility: FCCoC directory profiles should visibly show tier status, date of last renewal, last audit date (or “audit verified”), whether firm is under CAP or suspension. This builds trust for primes and agencies.
- Data-Driven Improvement: FCCoC should establish a dashboard to track key metrics across the registry, identify under-performing firms, emerging risk indicators (e.g., frequent change-orders, debarment flags), and provide benchmarking to firms to help them improve.
- Annual Review of Program: The Oversight Committee should approve any changes to criteria, benchmarks or process each year. Results of the review should be communicated to member firms.
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Consequences for Non-Compliance / Poor Performance
- Downgrade: If a subcontractor fails to respond to renewal audit requests, fails to meet benchmark thresholds, or incurs a major adverse event (e.g., suspension), FCCoC may automatically drop their tier status to the next lower tier (with notification).
- Probation: Prior to removal, a subcontractor may be placed on probation (e.g., 6 months) during which they must complete a CAP and demonstrate remediation. Their directory profile will show “On Probation” status.
- Removal: If probation period fails or serious misrepresentation or misconduct is discovered (e.g., false past performance claims, undisclosed debarment), firm can be removed from the Registry altogether (and delisted).
- Public Disclosure: FCCoC should maintain a “Registry Corrections & Removals Log” (perhaps member-only) that tracks firms removed or downgraded and the reason (with a redaction of confidential details as appropriate) — this builds credibility with primes/agency users of the directory.
- Re-application Process: After removal, a firm may re-apply after a defined “cooling period” (e.g., 12 months) and must demonstrate corrective actions/improved performance to be eligible again.
Communication & Marketing of Tier Status
- Each subcontractor should receive a digital badge (Tier 1, Tier 2, Tier 3) with a versioned expiry date (e.g., “Valid through 12/31/2026”) to place on their website, capabilities statement, marketing materials — similar to how Fortune 500 firms show “Supplier Excellence Rating”.
- The directory search results should allow prime contractors/agency users to filter by tier status, renewal date, whether audited, performance KPI summary (if available) — building a “fast trust filter”.
- FCCoC should produce an annual brochure or slide deck: “Why our Tier 3 Elite Subcontractors matter to primes and agencies” — featuring case studies of Tier 3 firms, performance outcomes, client testimonials.
- Provide onboarding webinars for subcontractors to understand the tier program, criteria, how to upgrade, how to maintain status, what KPIs matter and how to report/measure them.
- Encourage subcontractors to publicly highlight their “FCCoC Tier X” status in their marketing, emphasizing the rigorous standards, continuous monitoring, third-party oversight by the Chamber.
Implementation Roadmap
- Finalize Criteria & Benchmarks: Establish the final numeric benchmarks and criteria for each tier (Tier E, 1, 2, 3) and have the Oversight Committee approve.
- Build Registry Platform Enhancements: Update directory UI to show tier badges, renewal dates, audit status, filtering by tier/KPIs, visible “ON PROBATION” status if applicable.
- Develop Audit & Reporting Infrastructure: Create forms/templates for self-reporting, CAP submission, audit check-lists, KPI dashboards, reporting schedule.
- Train FCCoC Staff & Oversight Committee: On audit processes, data verification, metrics analysis, enforcement mechanisms.
- Pilot First Cohort Tier 2 & Tier 3: Select a sample group of subcontractors that meet the new enhanced criteria and move them through auditing, benchmarking, etc to validate process.
- Full Launch & Communication: Launch the enhanced program with marketing outreach to primes, agencies and subcontractors; publish FAQs.
- Annual Review & Reporting: Each year perform rollover renewals, audit cycles, publish performance report – adjust benchmarks as needed.
FCCoC subcontractor registry that is not just a directory, but a credible performance-management system.
