Small Business Administration Proposed Rule.13 CFR Part 121; RIN

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 businesses that outgrow the NAICS limits are punished for achieving the growth goals any business aims to accomplish. The language mandating contracts of “similar size and scope” is standard across the Department of Defense. Some contracting offices (e.g., SPAWAR and the U.S. Coast Guard) routinely assign minimum dollar thresholds for each past performance example, essentially cutting out mid-tier size firms from the competition.


Example: A company with annual receipts of, e.g, $30 million, isn’t even eligible to compete on a $100 million contract based on standard RFP requirements.



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Idea No. 220