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Federal Contracting

New Leadership for GSA

The White House has appointed new leadership to the General Services Administration (GSA), drawing heavily from the tech and finance sectors. On day one of the Trump administration, GSA welcomed its new team, including Stephen Ehikian as deputy administrator and acting administrator. (Federal News Network January 20, 2025)

Larry Allen, a longtime GSA expert, will become the associate administrator of the Office of Governmentwide Policy. Ehikian also introduced key political appointments: Josh Gruenbaum as commissioner of the Federal Acquisition Service, Mike Peters as commissioner of the Public Building Service, and Thomas Shedd as director of the Technology Transformation Service and deputy FAS commissioner. (ibid)

In an email message, Ehikian emphasized the GSA’s recommitment to its founding purpose of ensuring governmentwide efficiency and maximizing taxpayer value. “I recognize the critical importance of our agency’s mission and look forward to working together in the coming weeks to achieve it,” he stated. (ibid)

Ehikian outlined six guiding principles for the GSA:

  • Foster a culture of performance and accountability across federal government operations.
  • Eliminate waste, fraud, and abuse across the federal budget and processes.
  • Leverage best-in-class technologies to accelerate digital transformation and modernize IT infrastructure.
  • Uphold competitive principles that strengthen America’s economy, including fair and merit-based contract awards.
  • Promote “Made in America” policies to support domestic jobs and businesses.
  • Improve transparency, accountability, and collaboration within the GSA and with external partners. (ibid)

In a separate message, Ehikian detailed the agency’s future direction. He highlighted the GSA’s traditional role as a model of efficiency and pledged to refocus on streamlining government operations. “We will prioritize smarter, faster government services over larger, slower systems,” he explained. Ehikian also committed to aligning GSA priorities with the Trump administration’s objectives, such as:

  • Relocating federal operations from Washington, D.C., to regional facilities to boost economic opportunities nationwide.
  • Transitioning federal employees back to office environments to improve collaboration and accountability.
  • Supporting American innovation and removing ideological mandates, such as Green New Deal and ESG requirements, from construction and procurement policies.
  • Right-sizing the federal office portfolio by disposing of underutilized buildings and improving operational efficiency.
  • Enhancing transparency, accountability, and partnerships across government and industry. (ibid)

Ehikian acknowledged the dedication of GSA employees, attributing the agency’s transformation to their expertise and hard work. He announced plans for a new performance-based reward structure to align employee incentives with the agency’s mission. (ibid)

Ehikian brings extensive private-sector experience to his role, including positions at Salesforce and co-founding Airkit.ai, which Salesforce acquired in 2023. He also led RelateIQ, sold to Salesforce in 2014 for $390 million. Ehikian earned an MBA from Stanford and degrees in mechanical engineering and economics from Yale. (ibid)

Josh Gruenbaum, the new commissioner of FAS, joins GSA after serving as a director at the global investment firm KKR. This marks his first public-sector role following private-sector experience since graduating from NYU with dual MBA and JD degrees. (ibid)

Additionally, Ehikian named Frank Schuler and Michael Lynch as senior advisors in the administrator’s office and appointed Rusty McGranahan as general counsel. (ibid)

Questions concerning the changes at GSA and how your contract might be affected? Give us a call.

New SBA Recertification Rule Brings Major Changes for Small Business Contracting

On December 17, 2024, the Small Business Administration (SBA) implemented significant changes to its recertification rules, affecting small businesses and larger companies involved in mergers and acquisitions (M&A). These changes directly impact eligibility for new contracts and existing work under recertified business size or program statuses. Below are key highlights. (Pillsbury December 23, 2024)

New Terminology Clarifies Certification Status
The SBA’s new rule introduces disqualifying and qualifying recertifications and places them in the new section 13 C.F.R. 125.12. (ibid)

  • Disqualifying recertification occurs when a contractor certifies it is no longer small or eligible for specific small business programs. (ibid)
  • Qualifying recertification confirms that a business remains eligible for set-aside awards. (ibid)

A qualifying recertification allows businesses to compete for new set-aside orders for up to five years unless a disqualifying event follows. (ibid)

Timing for Size Determinations
The Small Business Administration’s (SBA) rule reiterates that size is determined at proposal submission, not at contract award. However, for most unrestricted multiple-award contracts (MACs), size is set at proposal submission for individual orders, except under the Federal Supply Schedule (FSS), where size depends on the latest recertification. (ibid)

Recertification Events (exceptions to the general rule)
Certain events trigger mandatory recertifications:

  • Mergers, acquisitions, or novations require recertification within 30 days of the event. (ibid)
  • Long-term contracts exceeding five years require recertification before the fifth year and each option period. (ibid)
  • Contracting officers may request recertification for specific orders or agreements. (ibid)

Impact on Set-Aside MACs

The new rule will prevent agencies from awarding new set-aside task orders or options after a disqualifying recertification under MACs. However, this prohibition will not take effect until January 17, 2026, giving businesses time to adjust. (ibid)

Transactions Between Small Businesses
If a merger or acquisition involves two small businesses, the contractor remains eligible for set-aside awards and options, though the contract terms may impose additional limitations. (ibid)

New Size Protest Rights
SBA now permits size protests for recertifications under MACs, empowering other contract holders to challenge competitors’ size status. (ibid)

Could you use some guidance navigating the new recertification rule? Give us a call.

The Army’s end of year checklist for Small Businesses

Prepare for success in 2025 by reviewing your business strategy and making key updates. Use this checklist to stay on track and position your business for growth.

  • Update Legal Documents and Certifications Keep your licenses, permits, and registrations current. Apply for SBA certifications at Certify.SBA.gov, and refine your Capability Statements to highlight past performance. (Army Office of Small Business December 23, 2024)
  • Explore New Contracting Opportunities Check Acquisition.gov and the GSA Forecast Tool to discover upcoming federal contracts. Use SubNet to find subcontracting opportunities posted by large prime contractors. (ibid)
  • Tap Into Mentorship and Support Connect with your local APEX Accelerator for personalized advice and free resources. SCORE Mentors offer expert insights on strategy, marketing, and operations. (ibid)
  • Plan Your Finances Review financial statements, gather tax documents, and visit IRS.gov for updates. Consider working with a tax professional to maximize deductions and stay compliant. (ibid)

Action taken today can lead to big successes in the year ahead. Find more information at army.mil/osbp. (ibid)

If you would like assistance updating licenses and permits, crafting a capabilities statement, or exploring new opportunities, give us a call.

The Rule of Two to Transform Small Businesses

The SBA proposed a rule on October 25, 2024, aiming to transform small business contracting by requiring agencies to apply the “Rule of Two” to task and delivery orders under multiple-award contracts (MACs). The Rule of Two ensures contracts go to small businesses when at least two qualified small firms can meet price, quality, and delivery standards. This rule will apply to orders exceeding the micro-purchase threshold, with exemptions for orders placed under the General Services Administration’s Federal Supply Schedule or in cases where there are supply chain risks or national security concerns. (HSToday.US November 7, 2024)

Driven by concerns over declining small business participation, the SBA estimates this rule could increase small business contracts by $6.1 billion annually. It supports the Biden administration’s goal of 15% federal contract spending with small disadvantaged businesses (SDBs) by 2025. In fiscal 2023, 28.4% of federal contract dollars went to small businesses, yet new entrants to federal contracting have dropped nearly 60% since 2010. (ibid)

The SBA proposal requires agencies to document their decision when they choose not to set aside a contract under the Rule of Two. Agencies must conduct market research, justify their rationale, and coordinate with small business specialists. For orders under MACs with fewer than two small business contract holders, agencies must explain their decision, with exceptions for contracts under the Federal Supply Schedule and other specific exemptions. (ibid)

This proposal builds on a January 2024 memorandum from the Office of Federal Procurement Policy, which directed agencies to document such decisions. The SBA aims to address inconsistencies in applying the Rule of Two, which arose from differing interpretations by the Court of Federal Claims and the GAO regarding its use in MACs.aiming to improve compliance and Public comments are open until December 24, 2024, with the SBA encouraging input from stakeholders. If adopted, the rule promises to level the playing field, boost small business participation, and diversify the federal supply chain. (ibid)

Questions concerning the Rule of Two? Give us a call.

Don’t lose your Federal Government business – add a backup

The days are getting shorter, and surprises lurk in the night. Don’t let missing your entity registration renewal stop you from doing business with the federal government—that’s scarier than anything else!(Buy.GSA.GOV October 10, 2024)

Here’s some good news: your current Entity Administrator can add one or more backup Entity Administrators today. They simply log in, choose trustworthy team members, and invite them to join as Entity Administrators. No tricks, no complicated approval process. The new admins will have the same permissions, so make sure they’re a good fit! If they need guidance, we’ve got easy-to-follow instructions ready.(ibid)

Don’t wait until the last minute—ask your current Entity Administrator to invite backups now. With extra admins in place, you’ll always have someone ready to renew your registration on time and keep business with the federal government running smoothly. (ibid)

Need some help adding additional Entity Administrators? Give us a call.