The VETS First Contracting Program was established by the VA to ensure the department’s adherence to the U.S. Supreme Court Kingdomware decision and mandates. This program outlines three key principles:

  • The “Rule of Two”: If at least two qualified SDVOSBs or VOSBs are capable of fulfilling a contract requirement at a fair and reasonable price, the contract must be set aside for those businesses.
  • Subcontracting Limitations: Contracts awarded to SDVOSBs and VOSBs as a set-aside requires that the SDVOSB/VOSB, or similarly situated subcontractors, receive at least 50% of the contract revenue to ensure these businesses are the primary beneficiaries.
  • Certification: The SBA maintains a rigorous process to certify businesses as SDVOSBs or VOSBs.

Currently, the micropurchase threshold is $10,000 for most supplies and services. It rises to $25,000 for construction projects and $2,500 for purchases by agencies outside the United States.

The “Rule of Two” does not apply to purchases under the micropurchase threshold. Here’s why:

  • Simplified Acquisition Procedures: Purchases under the micropurchase threshold fall under a streamlined process designed for very small acquisitions. This aims to minimize administrative burdens on both the government and sellers.
  • Focus on Efficiency: Demanding two responsible small business offers for micropurchases would be counterproductive, increasing the time and resources needed for such small transactions.
  • Fair Market Price: The main safeguard within the micropurchase process is the obligation of the buyer to ensure the price is reasonable. Agencies might rotate suppliers and conduct occasional price comparisons to achieve this.

Coley, an SDVOSB, has successfully assisted companies, both veteran and nonveteran, for over 20 years with navigating the complex world of Federal contracting.  Since our beginning, we have worked extensively with the VA National Acquisition Center.  Thus, we constantly monitor VA acquisition trends and policies and assist in identifying winning strategies to enter and succeed in that marketplace.

 One tool that may be of help is our FedMap Community at Membership is free and enables contractors to Learn, Network, and Thrive in the government contracts market. FedMap also offers one-to-one coaching by experienced Government Contracting experts to demystify Government contracting and help you develop winning strategies.  Our coaches have an average of 30 years’ experience in winning and managing government contracts. Find out more at

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