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 Proposed Rulemaking Regarding WOSB and EDWOSB Certification

February 16, 2016
PilieroMazza recently submitted comments on the U.S. Small Business Administration's Advance Notice of Proposed Rulemaking Regarding Women-Owned Small Business and...

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

Comments on the Proposed Rule Regarding Credit for Lower Tier Small Business Subcontracting

December 10, 2015

Includes:

  • Allowing goaling credit under single contract subcontracting plans for small business subcontracts awarded at any tier
  • Clarification of requirements for individual versus commercial plans
  • Requiring prime contractors to list NAICS codes for each subcontract solicitation
  • Permitting reliance on SAM representations

Comments on the Proposed Rule Regarding Small Business Subcontracting Improvements

August 10, 2015

Includes:

  • Establishing subcontracting goals in terms of total contract dollars
  • Contracting officers discretion
  • Prime contractor responsibilites
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