PilieroMazza recently submitted comments on the U.S. Small Business Administration’s Advance Notice of Proposed Rulemaking Regarding Women-Owned Small Business and Economically Disadvantaged Women-Owned Small Business—Certification issued December 18, 2015, 80 Fed. Reg. 78,984.

We represent many small business federal contractors, including women-owned and economically-disadvantaged women-owned small businesses (“WOSBs/EDWOSBs”). We submitted the comments to assist SBA in drafting a viable proposed rule that is fair and workable for WOSBs and EDWOSBs.

Click here to read our comments in their entirety:

  • 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

Please do not hesitate to contact Pamela Mazza, Jon Williams, Katie Flood or Megan Connor at (202) 857-1000 if you have any questions about these comments.

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