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.

 

 

New SIN for Office Admin Services

Under the new Multiple Award Schedule, GSA is changing the Special Item Numbers (SINs) in the Office Management and Human Capital large categories. GSA’s Northeast and Caribbean Supply and Acquisition Center and the Office of Customer and Stakeholder Engagement (CASE) are adding the new NACIS-based SIN56110 for Office Administrative Services. In addition, GSA is combining the two current SINs for Human Resources Line of Business into SIN 541612LOB. These changes all take effect on 1 July 2020. (GSA Interact June 24, 2020)

SIN 56110 will make it easier for searching and identifying specific support services to meet mission-critical needs. These services include a range of day-to-day activities, such as office administrative support, data entry, payroll administration, recordkeeping, travel preparation, scheduling, meeting management, purchasing supplies, and logistics.

To better meet agency needs, GSA is merging two SINs of the consolidated schedule, into one new SIN. The two SINs 541612OPM and 541612PSSC will be combined into 541612LOB. This new SIN provides technology solutions in support of other SINs in the Human Capital category. This category may include software, technology, systems, and related solutions. To be a function under this SIN, the services and products offered must support one or more of the 15 functions/54 sub-functions in the human capital lifecycle. To obtain a list of theses functions, visit the Human Capital Business Reference Model (HCBRM).

GSA is holding a webinar tomorrow, Friday, 26 June 2020, to review details and answer your questions. The link to join the webinar is https://meet.gsa.gov/r2newsins/. (ibid)

Questions about the Office Management and Human Capital large categories? Give us a call.