The Navy is looking to end Small Business subcontractor baiting

The Department of the Navy (DoN) has exceeded all of its small business goals for fiscal year 2021, spending more than $17 billion with small business prime contractors. The Navy is, however, wrestling with small business subcontractors getting their fair share. (Federal News Network October 21, 2021)

An updated effort to enforce small business contracting plans is in the works, according to Jimmy Smith, the director of the Office of Small Business Programs for the Department of the Navy. (ibid)

According to Smith, “the Navy executed a Navy audit, service audit on subcontracting on our 10 major buying commands. The Naval Sea Systems Command was the first of those 10 audits. The audit has concluded. We’ve already seen the results of that and now we’re sharing that information across the entire enterprise to go off and correct problems. We don’t think we’re going to learn anything more from going over the same information in the other audits, so now is the time to get into corrective actions and the steps that we need in order to execute solutions to problems instead of continuing to admire problems.” (ibid)

The first audit has provided some changes to be made Navy-wide, according to Smith. “First is reporting back to our industry partners. We have to make that something that’s pretty standard, maybe use a machine learning technology to help contracting officers identify problems that are in contractor performance assessment reporting (CPARs) when it comes to how well our industry partners are doing meeting their own subcontract and goals, that they can communicate it to us. We would love to have a system that flashed bright red lights when an industry partner wasn’t living up to the plan in the document that they provide to us about the health of their effort. Right now, it’s all hand-over-hand reading to see if you find that someone is off and then go do the analysis. I think we have to come up with a mechanism that brings the importance level of subcontract and compliance up to a higher level to raise it to the attention that it’s deserved.” (ibid)

Government agencies and prime contractors, need to hold up their side of the bargain and be held accountable. In 2018, the Inspector General for the Defense Department found it to be a challenge for five contracting commands to monitor prime contractors’ compliance with individual subcontracting plans. He told the House Small Business Committee the individual contractors who held subcontracting plans, did not meet their small business subcontracting goals. (ibid)

The Federal Acquisition Regulations Council issued a final rule in August. The rule requires large businesses to make “good faith efforts” to meet subcontracting goals. A few examples of actions that are a failure to make a good-faith effort can be found in the SBA’s guidance list. (ibid)

The final rule spells out what encompasses not making a “good faith effort”. The rule includes turning in subcontracting plan reports late, not designating an employee to monitor the subcontracting plan, and not completing market research. (ibid)

Smith said the Navy has met all of its small business goals for the past four years. He added, the Navy’s goals are not just the numbers, but providing the correct capability to the warfighter at the best value. (ibid)

Smith noted that the Navy is finding small businesses that meet their needs by an extended outreach effort. The move to virtual events has also extended their outreach. Virtual events are more cost-effective and reach more people. Smith plans to continue to do some live events, however, webinars will complement these and hopefully reach even more small business contractors. (ibid)

Questions about your small business subcontract plan? Give us a call.

 

 

Life after DUNS

If you have done any work, within the past 60 years with the Federal Government, then you have probably heard of the Data Universal Number System or DUNS. It is the data format that identifies organizations doing business with the government.

GSA, who administers the program, awarded a new contract in 2018 to Ernst & Young to dispense new organization identifiers. The new Unique Entity IDs (UEIs) will replace the current DUNS numbers. Ernst & Young will also manage the transition. (Nextgov October 13, 2021)

GSA is working with agencies to test the old and the new numbers prior to the final cutover, planned for April 2022. However, before the switch from DUNS numbers to UEIs takes place, GSA through the Integrated Award Environment program would like to work with some testers to ensure smooth sailing before the final cutover. (ibid)

According to Interact.gov, “volunteers get scripts which walk through various Unique Entity ID (SAM.gov) functions, such as requesting and receiving a Unique Entity ID (SAM.gov) or how to deal with error scenarios. Each test script takes about 20 minutes or less. You test at your own pace and send us your feedback.” This is extremely necessary because the DUNS is a nine-number string and the UEI is a 12-digit alphanumeric code. (ibid)

The program office recently released new help resources through the Federal Service Desk under a dropdown option under FAQ. It is also accessible through a large green button icon on the fsd.gov homepage. (ibid)

This large-scale modernization touches every single entity that does business with the federal government. GSA is hopeful their call for superusers will enable a smooth transition.

Questions about the UEI and how you might get ahead of the curve and get yours? Give us a call.