Comments on Notice–MV–2017–01, Evaluation of Existing Acquisition Regulations

August 15, 2017
The U.S. General Service Administration’s (“GSA”) is seeking input on acquisition regulations, policies, standards, business practices and guidance issued by GSA across all of its acquisition, disposal, and sales programs, that may be appropriate for repeal, replacement, or modification. We represent many small businesses that participate in the various procurement programs administered by GSA, in particular contract vehicles under GSA’s Federal Supply Schedule program. Although there are many issues that touch upon small business concerns that hold these contracting vehicles administered by GSA, we commented on the utilization of contractor teaming arrangements (“CTA”) for Schedule opportunities, and special small business considerations arising under these CTAs.

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
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