The $27.0 Million Size Standard and Past Performance Requirements. The majority of contracts in the Military Weapons exemption for NAICS Code 541330 code are so large that even though a firm may be considered “large” at 27.0 million, the firm often cannot meet the past performance requirements stipulated in Government Requests for Proposal (RFPs) which demand “contracts of similar size and scope.” Consequently, small ...more »
The $27.0 Million Size Standard and New Focus on Multiple Award Contract Vehicles. As the Federal Government moves toward awarding large-scale multiple award contracts while minimizing single award vehicles, businesses just surpassing size standards are forced to compete with much larger companies in order to secure these vehicles and maintain their business base. These vehicles have exceedingly high dollar thresholds ...more »
Make government small business offices and agency leadership responsible for success of small business contracts for the government agency rather than just repsonsible for tracking/meeting set-aside goals.
Your agency’s Office of Hearings and Appeals will not review an appeal where the contract has been awarded [13 C.F.R 121.1101(b)]. To correct the errors an SBA size determination in such a case the small business must proceed to Federal District Court (and incur additional legal expenses). In dismissing an appeal without review, the SBA lost accountability for its personnel who made the size determination and put additional ...more »
Limit federal employment to no more than 20 years of service for employees without commerical work experience. Require all federal procurement/contracting office, small business office including SBA, and senior leadership across all agencies to have a minimum of 5 years of commercial/industry experience.
Fix or do away with the Defense Contract Audit Agency (DCAA). They are unable to perform audits in a competent and timely manner delaying payment of hundreds of millions of dollars to small business.
Spend more effort on removing regulations from the FAR/DFAR than the effort spent adding to them and trying to manage government contracts according to them. Have government agencies apply common sense and sound ethics vice the present level of reliance placed upon the FAR/DFAR driven bureaucracy.
Develop strategies to ease burdens and enable small business government contractors to take their lessons learned from working with the government into commercial markets.
Remove from federal procurement regulations all "lowest common denominator" type regulations and give small businesses the benefit of the doubt. Ensure that federal procurement regulation actually achieve the intent behind the rule.
Have the SBA pay for small business legal cost to defend a size protest. This will encourage the agency to improve it's rules and understanding of how small and large businesses work together to be both profitable and productive suppliers to the government.
Increase periods of performance and/or award terms for small business contracts to allow small business time to mature and grow.
Moving towards shorter periods of performance, as the DOD is doing now, will not increase competition and lower costs. It will only increase costs and make it more difficult for small businesses to grow.
Effect of Size Standards on the Erosion of the Mid-Level Companies. In recent years, mid-size firms, by virtue of being neither small enough nor large enough to successfully compete, have consistently and considerably seen their share of the market decline, according to Gregory Sanders et al.’s report Structure and Dynamics of the U.S. Federal Professional Services Industrial Base 1995-2009 (see figure 3-14, Sanders et ...more »