By: Chris O’Donnell
June 8, 2014

I joined over 200 small businesses at the 7th annual conference. By a show of hands approximately 70 percent had received contracts from USAID. Overall the conference was very informative and professionally organized. While the FBO advertisement posted on Apr 29 and was scheduled to close on May 16, 200 slots were full by May 2 on a first come, first serve basis.

I attended last year and USAID has made significant progress to increase opportunities for small businesses. Among them, missions now have a 6.5 percent small business utilization goal. This may be unique in the USG as FAR Part 19 [Small Business Program], except for Sub Part 19.6 is not applicable outside the US. For 2014, each bureau and mission have its own goals. In the past when USAID did not reach its goal, no one bureau or mission could be held accountable.

Mr. Maurico Vera, Director of the Office of Small and Disadvantaged Businesses Utilization, mentioned thresholds on IDIQCs (for set aside for small businesses) are being reviewed as they may be set too low. One of reasons could be with the size standard increase from $7.0 to $14.0 million, small businesses are now managing larger more complex contracts. Also, in May 2013 the ceiling on women owned small businesses was lifted.

While it wasn’t clear as to the proposed IDIQC language, he may be referring to FAR 19.501 (e) which states, …Agencies may be establish threshold levels for review [for set asides] depending upon their needs.” FAR 19.501 can be complicated to understand and does provide considerable judgment to Contracting Officers to set aside awards to small businesses. Setting a fixed threshold may communicate to COs, not to consider making set asides at a higher threshold.

Mr. Calvin Jenkins, Deputy Associate Administrator for Government Contracting and Business Development, mentioned an SBA rule which requires Contracting Officers to be notified when subcontracting plans change. The rule was final over a year ago (July 2013) to implement provisions of the Small Business Jobs Act of 2010. It also adds a provision requiring a prime contractor to notify a contracting officer in writing whenever the prime contractor reduces payments to a small business subcontractor or when payments to a small business subcontractor are 90 days or more past due. This rule clarifies that the contracting officer is responsible for monitoring and evaluating small business subcontracting plan performance. For USAID, this is a significant shift in responsibility as the COR had been responsible for completing the contractor performance report to include the section on sub contracting plans. This signals a clear message, contracting officers, not the COR are more likely to protect small businesses interests in an approved sub contracting  plan.

He also mentioned a draft rule “out for comment” in the Federal Registry that allows the set aside requirement of 51% to be from similar organizations and not limited to one small business. I did a search of the Federal Registry and SBA has no rule currently posted for public comment. What is unclear, is the required relationship among small businesses bidding–would a prime-sub relationship be acceptable or would it require a joint partnership.

How is USAID doing on its small business score card? I did an internet search: FY12-B, FY11-A, FY10-C and FY09-F. Not posted are the FY13 scores or how each bureau and mission is doing reaching individual goals. This time last year FY12 scores were already posted.

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