My company won a ID/IQ contract with the VA and was eligible to compete for SDVOSB set-aside task orders. Two years later we are removed from CVE for becoming large.
After researching how to gain re-enlistment in CVE, I seem to have discovered a quagmire. There are SBA regulations that state you are considered small for the life of the contract, unless three events occur (none of which have in this case). Additionally, even if we are considered large, that determination is prospective only and will have no retroactive effect. By all accounts, the law says we should be eligible to compete for SDVOSB set aside task orders on this ID/IQ.
However, there is a VAAR clause that shows up in SDVOSB set aside task orders which states, and I am paraphrasing, any potential offerors must be listed in the VA's CVE database. It is my understanding that the CVE database is not contract specific. A company is either, broadly speaking, small or not small. That is to say, a company is not listed as an SDVOSB for contract A, but not contract B in CVE.
Broadly speaking, we are not a SB anymore, yet the law says we should be able to compete for SDVOSB set aside task orders.
So my question is, how does my company get re-listed in CVE? Would any petition for re-enlistment start with the CVE or SBA?
Thanks in advance for any suggestions.