SBALogoBeginning in 2014, the Small Business Administration is making some big updates to the regulations that govern Small Business contracting through the GSA Schedule. Review the full final ruling here.

The two main revisions to the regulations involve:

(1) Policies and procedures for setting aside, partially setting aside, and reserving Multiple Award Contracts for small business concerns

The SBA now has more specific procedures for setting aside Multiple Award Contracts that will now allow a Multiple Award Contract to be broken out and partially set aside for Small Businesses. If market research indicates that one small business will not be able to perform on the entire task order, Contracting Officers can now break out the task order by contract line item number (CLIN), special item number (SIN), functional area or sector and have only certain portions be set aside. In the past, the procuring Contracting Officer and the Small Business would have to go through a lengthy process to award/bid on only a portion of a contract. This new partial set aside procedure however now makes it mandatory for Contracting Officers to assign one, and only one, NAICS code to the CLIN, SIN, functional area or sector. The one NAICS code rule will help clear up any grey area in which some contractors may be considered both large and small on the same contract if there are multiple assigned NAICS.

(2) The recertification process for identifying your Small Business status.

The SBA has also made final decisions on when Small Businesses have to recertify their Small Business size. Currently, when a business is awarded a multiyear contract, they certify their status when they are first awarded and will be considered small for the life of the contract until option or renewal.  Although there were some arguments that businesses should have to recertify their size with every order because they may become a large business within the 5 year life of the contract, this rule will remain the same. The SBA ultimately decided that the current ruling “strikes the right balance.”

In addition, when a business is acquired by another business they are currently required to re-certify their business size, however, the business that acquired the other business does not have to recertify. This rule is changing. The SBA will now require both parties to re-certify after an acquisition. SBA feels that if a business is acquired or if a business acquires another company it should recertify its size as this is a major business event.

Other Changes to Consider

If your business is approaching its 5 year renewal period or if your business has acquired a company or has been acquired you will have to recertify your business size. The certification of your business size is done through your System for Award Management (SAM) account and is based on the NAICS you have input into your SAM profile.

If you are a small business these changes can mean more opportunities for you!  Press your network and keep you bid team on alert for developing opportunities. If you have any questions on recertification or these updates to the SBA policies/procedures for Small Business contracting, feel free to contact us.

 

 

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