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Tag: SBA

Just the Facts FAS, Please

Earlier this week, a GSA watchdog discovered erroneous reporting of small business contracts by the Federal Acquisition Service (FAS). (Government Executive September 17, 2020)

The General Service Administration (GSA) inspector general (IG) recently provided a report that focused on the data entered into the Federal Procurement Data System – Next Generation, which is managed by GSA. The Small Business Administration (SBA) uses the system data provided to determine if the federal government is achieving its annual goal of awarding 23 percent of contracts to small businesses. An IG review of FAS procurements from fiscal 2016 and 2017 and shows that small business procurements have been grossly overstated.

“We found that FAS’s reporting of small business procurements contained significant inaccuracies. We identified $89 million in procurements erroneously recorded as small business in the Federal Procurement Data System – Next Generation. Additionally, FAS’ small business procurement reporting does not identify the extent of the work performed by large businesses. We found approximately $120 million of small business procurements in which large businesses performed a portion of the work.” (ibid)

After interviewing small business contractors and GSA officials as well as analyzing agency contracting data, the IG determined many of the issues to be out of GSA’s control. For instance, the IG found that classification codes  often “pre-populate” for task orders; due to the nature of the software, officers cannot override the system to update the task order codes. In addition, no mandate exists for FAS or small businesses to report how much of the work completed on a contract is subcontracted to large businesses. This leads to inaccuracies when assessing FAS’s small business procurements. Many believe the inaccuracies will never be fully fixed due to the competing policy issues and marketplace anomalies. (ibid)

The IG recommended the following:

  • Fix the limitations of the contracting system to enable accurate reporting
  • SBA and the commissioner discuss how subcontracting and reseller agreements are reported

How does this affect your contract or an upcoming proposal? Give us a call.

SubK Silver Lining

The U.S. Small Business Administration (SBA) is extending the time for contractors to file Individual Subcontracting Reports (ISR) by 30 days and Summary Subcontracting Reports (SSR) by 60 days. (Small Business Administration Extension Notice, August 27, 2020)

SBA reasoned that, due to the pandemic and social distancing requirements in a number of states including the District of Columbia, many records remain unattainable. Without proper records, contractors are not able to meet reporting requirements.  New deadlines for ISRs is 30 November 2020 and for SSRs is 30 December 2020. SBA is also extending the deadline to 30 November for vendors who have recently completed contracts or will complete contracts before 30 September. No financial or liability consequences will be imposed on contractors for taking advantage of the updated deadlines.

The extension notice is being sent to those on the SBPAC list as well as all government and business personnel with a valid email in eSRS. (ibid)

Not sure if the extension notice applies to you? Give us a call.

GSA, Pandemic Style

GSA is moving quickly to enact several initiatives while responding to the COVID-19 pandemic. Because the current state of emergency necessitates the Federal Acquisition Service to purchase medical supplies and other equipment at a fast clip, Contracting Officers have no choice but to react with a fair amount of speed and flexibility. (Federal News Network, May 1, 2020)

This includes:

  • changing policies for prompt payment and onboarding/offboarding of contractors
  • construction of the new e-commerce marketplace platform, which was paused during the first few weeks of the pandemic, is now moving forward, albeit at a much slower pace
  • monitoring other initiatives possibly impacting by the pandemic, such as Enterprise Infrastructure Solutions (EIS)
  • continuing corrective actions on Alliant 2 revised proposals
  • expanding the small business innovation research (SBIR) program, part three

Some government markets, like travel, have declined; however cleaning products and enhanced screening services have increased exponentially. (ibid)

Any questions about getting your product or service in front of government buyers? Give us a call.

PPP Payback?

Last week, the Small Business Administration (SBA) launched a second round of the Paycheck Protection Program. PPP allows banks to “forgive” government-guaranteed loans to small businesses struggling due to the pandemic. Unfortunately, government guidance on necessary documentation/calculations to ensure forgiveness is sorely lacking.

Many small business owners expect their loans to ultimately be forgiven “but it is not that simple,” according to Paul Merski, of the Independent Community Bankers of America. He advises that everyone keep “their information and paperwork in order.”(Reuters, May 1, 2020)

The PPP regulation states the following:

  • Borrowers must spend 75 percent of the loan on payroll costs like salaries, tips, leave, severance pay, and health insurance, within the first two months.
  • Borrowers must spend the remaining 25 percent on other “running” costs, such as utilities and rent.

All money spent on non-qualifying expenses must be repaid within two years at a one percent annual interest rate. (ibid)

Confusion and uncertainty surround the re-payment or forgiveness process itself. Who certifies that borrowers actually meet the 75 percent threshold and using borrowed funds as required? Will SBA will issue standard guidelines for forgiveness? Small business owners need to know which documents to maintain and records to keep. EZGSA, like all of you, await some clarity on next steps.

Are you unclear on your Small Business loan payback? We will let you know as soon as we do. In the mean time, feel free to give us a call.

Bye Bye Self Certify

Certification changes for Women-Owned Small Businesses (WOSBs) and Economically Disadvantaged WOSBs (EDWOSBs) will occur this summer. The Small Business Administration (SBA) expects the updated regulation to be published on 30 June 2020, and to go into effect 30 days after. (U.S. Small Business Administration)

Info we have so far includes:

  • Self-certification as a WOSB or EDWOSB will end
  • Certification, going forward, will be accomplished through an approved third-party entity or through SBA’s free online certification at certify.sba.gov. (ibid)

To assist in awarding women-owned business contracts, the government limits competition, by including just those businesses participating in the women’s contracting program. The goal of the government is to award the contracts to women-owned businesses in industries where WOSBs are underrepresented. Some contracts are restricted even further to include economically disadvantaged women-owned small businesses (EDWOSBs) only. The SBA keeps a current list of those eligible industries. (ibid)

Eligibility for the women’s contracting program:

  • Qualify as a small business
  • Company at least 51% owned and controlled by women who are U.S. citizens
  • A company with the day-to-day management of operations and long-term decisions controlled by women

Eligibility for the economically disadvantaged business within the women’s contracting program:

  • Meet all requirements of the women’s contracting program
  • Business is owned/controlled by one or more women, each with a personal net worth less than $750,000
  • Business is owned/controlled by one or more women, each with $350,000 or less in adjusted gross income averaged over the previous three years
  • Business is owned/controlled by one or more women, each $6 million or less in personal assets

The eligibility requirements are spelled out in Title 13 Part 127 Subpart B of the Code of Federal Regulations (CFR). (ibid)

To participate in the women’s contracting program, you must be certified as a women-owned business. First the company must have a profile on SAM.gov, and then go through the aforemention process at certify.SBA.gov. The SBA has approved the following four organizations to provide third-party certifications:

Updating certification information annually through both SAM.gov and certify.SBA.gov will maintain your status within the program as well as make contracting officers aware that your business meets the eligibility requirements to compete under the WOSB or EDWOSB umbrella.

Questions about self-certification, third-party certification, or the women-owned business contracting arena? Give us a call.