Subcontracting with CAGE Codes: What Primes and Subs Need to Know

Subcontracting is how large federal programs get done. Prime contractors win major awards and then distribute work to a network of subcontractors with specialized capabilities. For small businesses, subcontracting can be a path to building past performance, gaining clearances, and developing relationships that lead to future prime contract opportunities. CAGE codes are the thread that connects all parties in this ecosystem.

Small Business Subcontracting Plans

Federal Acquisition Regulation (FAR) Subpart 19.7 requires prime contractors receiving awards over the simplified acquisition threshold (currently $250,000) to make maximum practicable use of small businesses. For contracts over $750,000 ($1.5M for construction), individual subcontracting plans with goals are required. These plans must list anticipated small business subcontractors by CAGE code and category (small business, 8(a), HUBZone, SDVOSB, WOSB).

FSRS Reporting

The Federal Subaward Reporting System (FSRS) is where primes report actual subcontract awards to first-tier subcontractors. Each report requires the subcontractor's CAGE code, UEI, and award amount. Contracting officers and SBA review FSRS data to verify that primes are meeting their subcontracting plan goals. Inaccurate CAGE codes in FSRS reports trigger correction requests and can damage the prime's performance evaluation.

Finding Subcontracting Opportunities

Small businesses seeking subcontracting opportunities should identify prime contractors active in their NAICS codes. Search FedAtlas.com by NAICS code to find the primes receiving the most awards in your target categories. Once you have a list of target primes, decode their CAGE codes on our CAGE Code Decoder to get their company name and contact information, then reach out to their small business liaisons.

Subcontractor CAGE Code Verification

Before including a subcontractor in a proposal or awarding a subcontract, verify their CAGE code status. An inactive SAM.gov registration cannot receive subcontract payments through WAWF. Check for active registration, verify socioeconomic status if relevant to your plan, and review past performance. Our vendor verification guide covers the full checklist.

Teaming as a Subcontractor First

Many small businesses build their federal track record as subcontractors before pursuing prime awards. Relevant experience as a subcontractor can be cited in past performance sections if you can obtain permission from the prime and have documented your performance. Your CAGE code accumulates a history of federal relationships — contracting officers evaluating your proposals will see agencies, NAICS codes, and dollar volumes associated with your CAGE code on FedAtlas.com.