Increase contracting opportunities not limit them!
Category Management is an acquisition strategy used by the federal government on 10 categories of goods and services, seeks to reduce government buying through direct contracts, reduce acquisition costs and bolster buying through larger contracts and/or task orders. This strategy will make it more challenging for small businesses to compete. Fewer small business awards not only limits the supply of vendors to the government, the ripple effect limits the ability of small businesses to grow through federal contracting. Since the government has never met its HUBZone goal of 3%, the Council is dedicated to fighting for government acquisition practices that maximize our ability to compete, not limit them.
Expand the DBE Program definition to include HUBZone & SDVOSB
Currently HUBZone and Veteran owned SBC are excluded from bidding opportunities under the DBE program. By expanding the DBE program definition, Congress could generate approximately 20,000 new jobs for small businesses by awarding them $2.5 billion more in contracts (based on Federal Highway Administration data). These jobs are especially important for veterans and residents in low‐income and high‐unemployment neighborhoods (HUBZones). We urge Congress to level the playing field for the unemployed, under‐employed, and small businesses by updating the DBE definition in MAP‐21 to include SDVOSBs and HUBZone companies to create thousands of new jobs for the citizens who need them the most – service‐disabled veterans and the unemployed and underemployed living in the nation’s poorest rural and urban communities.
Extending the Rise Act to include Large Business subcontracting goals.
The HUBZone Council supports legislation to amend the Recovery Improvements for Small Entities After Disaster Act of 2015 (RISE Act) to include large business subcontracting goals. The Rise Act authorizes SBA to establish contracting preferences for small businesses located in disaster areas, including HUBZone firms, and give agencies double credit for awards to these small businesses that are located in the Providentially declared major disaster areas.
According to FPDS & USASpending, many of the larger contracts are being solicited through existing vehicles, thus it is reasonable to assume that by extending the legislation to subcontracting goals, the number of contracting opportunities to local businesses would increase significantly. Many of the small businesses operating within disaster areas may lack the bandwidth, resources, or bonding capacity required to prime these contracts, which is due, in part, to contract bundling and strategic sourcing, etc. In addition to increasing localized spending, this provides an opportunity for these small businesses to build lasting relationships with other companies which could lead to future contracting opportunities or even mentor-protégé relationships.
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PRICE EVALUATION PREFERENCE
The HUBZone Council believes that the 10% price evaluation should be applied at the task order level for BPA's and IDIQ's vs at the time of contract award.
Reduce regulatory burdens and expand sole sourcing.
The Council supports reforming the structure of the sole source requirements, allowing agencies to leverage sole source authority in order to meet the HUBZone small business goals. The Council believes that there should be parity among the SBA program as it relates to sole sourcing.
Reform & Enforcement
With Category Management reducing the number of contracting opportunities available to small businesses, subcontracting reform and enforcement is more important than ever. It is critical that we look for ways to reward those companies that adhere to subcontracting plans and issue work-share and penalize those that do not. In order to sustain our industrial base is is ESSENTIAL that we develop a system that can effectively monitor subcontracting along and implement ENFORCEABLE standards.
The HUBZone program is the only small business contracting program that requires eligibility at the time of bid and award. The HUBZone Council believes that award eligibility should mirror other programs by only requiring eligibility at the time of bid only.
ATTEMPT TO MAINTAIN
HUBZone Small businesses are only able to claim attempt to maintain when performing on HUBZone set-aside contracts. The HUBZone Council believes that if the Government is counting the contracting dollars to the HUBZone small business goal then the small business should be able to claim safe harbor so long as SBA finds a way to publicly identify those companies claiming safe harbor.
Ensuring similarly situated language makes it into the FAR.
The delay in implementing similarly situated is causing significant issues for the small business community. With contract bundling and strategic sourcing, teaming strategies are more important than ever for small businesses to stay competitive within the market. It has been almost 2 years since SBA recognized similarly situated entities to meet performance requirements; however, it still has not been incorporated into the FAR.