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.

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.

Our Comments in Response to FAR Case 2015-15 Regarding the Federal Strategic Sourcing Initiative - FSSI

August 19, 2016
PilieroMazza recently submitted comments to the General Services Administration stating that the proposed rule should not be applied in small...

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
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