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.

 

 

GSA is about to make Cloud purchases a whole lot easier

GSA is about to reveal a plan for a governmentwide marketplace for cloud solutions. This new marketplace will not only make it convenient, it will also set up a one-stop-shop for agencies to purchase commercial Software as a Service, Infrastructure as a Service, and Platform as a Service, offerings. (FedTech October 7, 2021)

On a recent webinar, Laura Stanton, assistant commissioner for the Office of Information Technology Category in the GSA’s Federal Acquisition Service, said, “We’re looking at how we put together a cloud marketplace that then becomes a buying platform for agencies. We want to put together not just a framework, but a market contractual vehicle that will allow our agencies to buy these core cloud services that we’re seeing them need more and more.” (ibid)

The GSA marketplace will provide agencies with professional IT services as well as post-award contract management tools. It would also set the requirements to verify cloud services meet the baseline security and adherence to guidance from the Federal Risk and Authorization Management Program (FedRAMP). (ibid)

GSA wants to streamline the entire cloud procurement process for agencies. According to Laura Stanton, “GSA uses the cloud and cloud-related IT professional services special item number (SIN) 518210C as a vehicle for multiple-award procurements. The contract type can be used to acquire cloud computing services, as defined by the National Institute of Standards and Technology.” Stanton said that GSA is “hearing that agencies have to go to multiple places to buy cloud. We decided it was time to take the next step.” (ibid)

An RFI is expected early in the new fiscal year, which began October 1, 2021. (ibid)

Questions concerning the upcoming RFI? Give us a call.

The 8(a) Business Development Program – the resource you didn’t know you needed

GSA shows its commitment to small businesses through the many resources made available to them. One beneficial resource which the Small Business Administration (SBA) has put into place is the 8(a) Business Development program. (GSA BLOG September 15, 2021)

The 8(a) Business Development program provides a fair and equitable opportunity for small businesses owned by socially and economically disadvantaged people or entities. The government does this by limiting competition for specific contracts to businesses that participate in the 8(A) Business Development program. (ibid)

Disadvantaged businesses the 8(a) program can take advantage of the following:

  • Competition for sole-source and set-aside contracts
  • Retention of a Business Opportunity Specialist to help navigate the federal contracting arena
  • Joint ventures with well-established businesses through the SBA’s Mentor-Protege Program
  • Management and technical support, business training, marketing assistance, and counseling (ibid)

Eligibility requirements for 8(a) status:

  • Meet small business size standards
  • No previous participation in an 8(a) program
  • The small business must be at least 51% owned/controlled by U.S. citizens who are economically and socially disadvantaged
  • Personal net worth must be $750K or less
  • Exhibit good character and the ability to perform on contracts (ibid)

All prospects for the 8(a) Business Development program must be certified in order to participate.

Questions concerning your 8(a) small disadvantaged business status or how to go about being certified? Give us a call.

 

 

The Department of Defense is making Small Business their business

The Federal Register recently posted a request for comments which stated, “The participation of dynamic, resilient, and innovative small businesses in the defense industrial base is critical to the United States’ efforts to maintain its technological superiority, military readiness, and warfighting advantage. The department seeks public input on the barriers that small businesses face in working with the department. This input will be used to update the department’s Small Business Strategy led by the Department of Defense (DoD) Office of Small Business Programs.” (Nextgov September 15, 2021)

DoD is looking to reinforce President Biden’s executive orders supporting underserved communities while promoting American competition. Some specific areas of exploration are:

  • What regulations or business practices hinder the relationship between small businesses and the government?
  • How do the department’s initiatives (The Mentor-Protege Program, Indian Incentive Program, Procurement Technical Assistance Centers, the Rapid Innovation Fund, Small business Innovation Research and Small Business Technology Transfer), support or impact small businesses?
  • How do contracting timelines impact small businesses?
  •  Are skilled workforces attainable to “sustain a competitive small business ecosystem?”
  • How the coronavirus pandemic has impacted small businesses in the defense industrial base. (ibid)

At a recent Pennsylvania Showcase on Commerce, Defense Deputy Secretary Kathleen Hicks said, “over the past decade, small businesses in the defense industrial base shrunk by over 40%. The data shows that if we continue along the same trend, we could lose an additional 15,000 suppliers over the next 10 years.” She noted that the department is committed to making it more straightforward for small businesses to win contracts and referenced the Request for Comments notice in the Federal Register.

President Biden is “committed to nurturing small businesses that have faced historic barriers in rural and urban America, including businesses owned by veterans, women, and people of color-especially Black, Latino and Asian American businesses.” President Biden’s goal is to double the number of federal contracts awarded to small and disadvantaged businesses, in the next few years.

The Department of Defense is looking for input by October 25, 2021, to their Request for Comments. If you have questions about the RFC or are looking to work with the DoD or other government agency, give us a call.