Comments Submitted in Response to RIN 9000-AN35: Revision of Limitations on Subcontracting

February 4, 2019
On February 4, 2019, PilieroMazza submitted comments on RIN 3245-AG86, Proposed Rule National Defense Authorization Acts of 2016 and 2017, Recovery Improvements for Small Entities After Disaster Act of 2015, and Other Small Business Government Contracting.

Includes our comments on:
  • We Support the FAR Council’s Revisions to FAR 52.219-4, But This Clause Requires Further Modifications to Align with SBA’s Limitations on Subcontracting Rules for HUBZone Joint Ventures
  • The FAR Council Should Propose Revisions to the HUBZone Price Evaluation Preference Clause
  • The Proposed Nonmanufacturer Rule FAR Clause Needs Revision to Conform to SBA’s Nonmanufacturer Rule
  • The Limitations on Subcontracting Should Not Be Applied to Any Contracts Below the Simplified Acquisition Threshold 

Comments Submitted in Response to RIN 3245-AG86—Proposed Rule on Small Business Government Contracting

February 4, 2019
On February 4, 2019, PilieroMazza submitted comments on RIN 3245-AG86, Proposed Rule National Defense Authorization Acts of 2016 and 2017, Recovery Improvements for Small Entities After Disaster Act of 2015, and Other Small Business Government Contracting.

Includes our comments on:
  • SBA’s Proposed Changes About Subcontracting Plans Provide Necessary Clarification
  • SBA’s Contracting Preferences for Small Businesses in Disaster Areas Are Welcome
  • SBA’s Clarification Regarding the Nonmanufacturer Rule and Information Technology Value Added Resellers Is Beneficial
  • Setting Aside an Order Under a Multiple-Award Set-Aside Contract
  • SBA Should Provide Further Clarifications to Its Proposed Rule on Recertification of Size and Status
  • SBA Should Not Require Mandatory Limitations on Subcontracting Compliance Disclosures
  • Exclusions from the Limitations on Subcontracting Calculation Are Welcome
  • SBA’s Proposed Changes to the Ostensible Subcontractor Rule Are Unnecessary and Will Harm Small Businesses
  • SBA Reasonably Proposes to Remove the Kit Assembler Provision
  • The Proposed Clarification About when Size Is Determined Is Helpful
  • Clarification Where One Acceptable Offer Is Received on a Set-Aside
  • The SBA Should Repeal the Presumption That Minority Shareholders Control a Business when No Majority Shareholder Exists

Comments Submitted in Response to RIN 2900-AQ24—VA Acquisition Regulation

January 25, 2019
On January 24, 2019, PilieroMazza submitted comments to the U.S. Department of Veterans Affairs in response to the proposed rule issued on November 29, 2018, RIN 2900-AQ24—VA Acquisition Regulation: Environment, Energy and Water Efficiency, Renewable Energy Technologies, Occupational Safety, and Drug-Free Workplace; Protection of Privacy and Freedom of Information; Other Socioeconomic Programs; and Contract Modifications. 

Includes our comments on:
  • VAAR Part 826 Will Be Beneficial, But It Needs Further Clarification
  • The VAAR Must Fully Implement the Vets Act Priority for SDVOSBs and VOSBs
  • When applying the full and partial credit for SDVOSBs and VOSBs under subsection (b) in a procurement where price is the only factor or that uses a lowest price technically acceptable source selection process as described in FAR 15.101-2, the contracting officer must deem the price offered by a verified SDVOSB to be 10% lower than its proposed price for evaluation purposes. The contracting officer must deem the price offered by a verified VOSB to be 5% lower than its proposed price for evaluation purposes.

Comments Submitted in Response to SBA's Proposed Rule on the HUBZone Program, RIN 3245-AG38

December 28, 2018
On December 27, 2018, PilieroMazza submitted comments to the U.S. Small Business Administration’s proposed rule regarding changes to the HUBZone Program. The proposed rule outlines a comprehensive overhaul to the program’s current eligibility and compliance requirements.


Comments Submitted in Response to RIN 2900-AQ20—VA Acquisition Regulation: Contracting by Negotiation; Service Contracting

November 6, 2018
On September 7, 2018, the U.S. Department of Veterans Affairs' ("VA") issued proposed rule , RIN 2900-AQ20—VA Acquisition Regulation: Contracting by Negotiation; Service Contracting. PilieroMazza submitted comments to the proposed rule on November 6, 2018.
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