Office of Management and Budget ( OMB ) Circular A-xxx

November 7, 2016

Includes our comments on :

  • Aspects of the Circular Require Clarification
    • We recognize that OFPP sees a value in Category Management and intends to institutionalize Category Management principles across the Government. However, clarification of the Government’s approach, as set forth in the proposed Circular, is needed.
  • Consideration of Small Businesses Should Be Required
    • More consideration of small businesses is needed.
  • BIC Sourcing Solutions Must Be Readily Attainable
    • The Circular does not address how competitions for BIC preferred and BIC mandatory sourcing solutions will be conducted.

Comments on FAR Case 2015-015 Regarding the Federal Strategic Sourcing Initiative - FSSI

August 19, 2016

Includes comments on FAR Case 2015-015

  • The Proposed Rule Should Not Be Applied in Small Business Set Asides
  • The Brief Analysis Should Allow for Flexibility
  • The Notice of Proposed Rulemaking Understates the Impact on Small Businesses

Comments on Proposed Rule Regarding Electronic Filing System and Filing Fee

May 16, 2016

Includes comments on:

  • Filing Fee
  • Redactions

Comments on Advance Notice of Proposed Rulemaking Regarding Women-Owned Small Business and Economically Disadvantaged Women-Owned Small Business Certification

February 16, 2016

Includes comments on:

  • SBA Should Delay Implementation and Work to Change the Law
  • SBA Certification Program
    • If SBA Adopts the Certification Requirement, SBA Should Be the Only Certifier
    • Streamlined Application Process
    • Concurrent Certification Through 8(a) Program
    • Term of SBA Certification
  • Third Party Certification
    • New Regulations & Procedures Are Needed if SBA Permits Third Party Certification in Addition to SBA Certification
    • All Certifiers Should Apply or Re-Apply
    • Term of Third Party Certification
    • No Repository Access for Third Party Certifiers
    • Mentor-Protégé Agreements and Joint Venture Agreements
    • SBA Should Clarify Applicability of the Certification Requirement to WOSB and EDWOSB Industries
  • Certification by States and Other Federal Agencies
    • State WOSB/EDWOSB Certification Authority
    • Acceptance of DBE Certifications in Determining Ownership and Control
    • State Entities’ Expertise
    • Other Federal Agency Certification, Including Contract-Specific Certification
    • WOSB/EDWOSB Protests of Firms Not Certified by SBA

Comments on U.S. Department of Veterans Affairs' Proposed Rule to Amend the VA's VOSB Verification Program

January 5, 2016

Includes comments on:

  • Section 74.1, Definitions
  • Section 74.2, Eligibility Requirements for VetBiz Vendor Information Pages (“VIP”) Verification Program
  • Section 74.3, Unconditional Ownership
  • Section 74.4, Control
  • Section 74.5, Affiliation
  • Section 74.14, Reapplication for Program Admission
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