Fred

There is an expectation of the price being fair and reasonable. You might affirm your IGE since SBA might question that. But if the price is too high, SBA should allow you to withdraw the offer - but with use of some other small business program as indicated by your research.

We are considering doing a SATOC small business set-aside for construction rather than MATOC. The Defense consolidation memo of October 28, 1996 would indicate this is a consolidation even though it is for construction. Value overf $25M. Though it would be "new" work because it is construction, it is work that could be performed by smalls. Should this be subject to a consolidation analysis and if so, would this a quantitative justification to show the benefits. The Jobs Act refers to this but does not seem clear. Thanks.

High Plains Computing, Inc. d/b/a HPC Solutions. Where GAO rules again on this.

All of this is good, but the question still comes up. There is somewhere a specific GAO ruling on this matter and i cannot find it, back from CCR days. But i did find this SBA ruling. Size Appeal of SoftConcept, Inc., SBA No. SIZ-5197 (2011). This does the job.

This looks to be in place now. Helps make some things clearer as stated above.

It appears that the use of FAR 19 abroad is a matter of agency preference. So do. So don't. Some agencies are not consistent in how they approach this. SBA chimes in on it being applicable i think.

Sole source is not allowed on the FSS. The FSS might be a means to identify an 8(a), but then the regular 8(a) procedures are utilized at FAR 19.8. Competitive is allowed on the FSS. One follows the same proceudres as one does with anycompetitive, but specifies with the communication to SBA that the work is on the FSS. See 13 CFR 124.503(h)(2).

The answer should be "yes". Sometimes contracting staff need to be reminded. This is still an unrestricted acquistion.

EIs do not fit really very well into FAR 19.7 but do it. would agree with contractor100.

This would be something both DCMA and SBA would downgrade for in a review, for what that is worth. Any waiver granted up front should be communicated to SBA as they review plan for advisory comments. I am not sure what authority one would cite for documenting this waiver.

DoD and NASA seem to have the most formalized approach. Other agencies may utilze as in he case you reference. The plans are really not supposed to be different. Participation is an evaluation factor that is to roll into the sub plan. The TCV dollars of participatio become 100%of the dollare to be subcontracted to small.

Actually knowing of the relationship of a GOCO to FAR 19 and the Small Business Act is of interest and not obvious in research. Perhaps there is no relationship.

It may be useful to review FAR 19.203 here, where the relationship between small business programs is described.

Does FAR 19.7 not place the burden of written self-certification on the small? It makes the written determination. It seems like it would be difficult for such a firm to compete but that would be a decision of the prime and it's needs.

Coming in late here, the first contracting officer where a plan is submitted approves the master plan. It seems like the master plan is almost a corporate policy statement. Then the goals for the individual contract are negotiated. It seems many universities use such plans. An advantage to this is that there is one template for all plans. One would hope the matter would be well done, concise, and with all eleven elements clearly identified. If one is anticipating this before even needing it, one cannot help but wonder if federal smalls are already being cultivated into the supplier base.