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.