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About DWGerard1102

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  1. To the OP, You will need to speak with the SBA 8(a) and HUBZone offices as both of those organizations have very specific requirements for their programs. The novation means that the newly formed company has to recertify for the HUBZone program (13 C.F.R. § 126.619(3)) and for the 8(a) program (13 CFR § 121.404(g)(1)). The Contracting Officer may or may not be familiar with those requirements.
  2. I would hope that at least some agencies conduct training for the clients and customers, but I doubt that is the case. I have offered training for years to the 1102 and program folks for the agencies that I support as a SBA Procurement Center Representative and all I have gotten (with two exceptions), is a big, hollow, empty nothing in return. Given that anything I present is worth CLPs and is free of cost, that baffles me. If contracting offices won't push training for their own staff, its not likely they are emphasizing it for their clients and customers.
  3. C Culham the SBA does not care if the FAR does or does not support its rules, the COC process is theirs and they use 13 CFR and not the FAR for their regulations. I have brought up that problem (Agencies use the FAR and the SBA ignores the FAR most of the time), but have not had a lot of success. At least once I have had a FAR regulation in hand but the SBA leadership would not even look at that cite, and relied purely on an attorneys opinion to make a rule (not a regulation, and not even written down at the time), that was contrary to the FAR regulation. In this case the Contracting O
  4. I checked with the COC Specialist in my Area and here is what he said: Chapter 4 of the COC SOP allows a partial award if the contract allows for award less than the full amount. 9. Can the COC Specialist or FS Recommend a Partial Award of a Contract? a. Yes, both the COC Specialist and FS can recommend a partial award provided: (1) The solicitation has a provision which allows for the contract award method; and (2) The SB has the capability to perform at the anticipated reduced level. 12 CFR125.5(f)(3) states (3) Where a contra
  5. I work at NASA, so I am on a mandatory work from home(WFH), right now. My WFH may go longer because of my cancer treatment program which puts me into a different category.
  6. In my experience your agency is the outlier; none of the agencies I have worked at (8 places, CA, DC, GA, TX, FL, AL), required overtime for half the year. Only 1 (a base support contracting office), required overtime in September, with optional overtime beginning in August. Most of the offices I worked in did not have any mandatory overtime, even those with predominantly one year funding. The offices working with more multiple year funding like the one I am in now are like "October is coming soon? How cute!"
  7. If you are the KO then you can submit the Size Protest as soon as the contractor is designated as the apparent awardee. Just let the size specialist know that the protest is from the KO and not from another competitor so they know not to impose that rule. The rule that states the award has to be announced prior to the protest being submitted is for when other competitors protest to the KO prior to award. I used to work as a size specialist for the SBA before they removed that program from the PCR duties.
  8. One factor in your corner is the SBA Procurement Center Representative (PCR) for your agency. The PCR has some authority that you as the Small Business Specialist do not have, primarily the ability to negotiate from an outside position which eliminates the "disagree with me and it will be reflected in your evaluation this year" problem and ultimately, the SBA Form 70 which is the equivalent of a tactical nuclear weapon in the Contracting process. A SBA Form 70 will stop the process in its tracks and if the dispute is not resolved at the HCA level, elevates it to the Agency HCA and the Secret
  9. My case is unique in that I work remotely 100% of the time; my boss is in different state than the one where my office is located, about 200 miles away. Everyday is a kind of telework as the clients that I service all send their documents to me via email and other document handling systems save one, my office is located in that one client who brings me their documents by hand. I have seen my supervisor face to face about 2-3 time per year since I took this job, one year it was zero times when she was going through a health issue. I see my clients face to face (other than the client that
  10. In that case the contractor may have exceeded its small business size standard due to its affiliation with the company that bought the company stocks. You should contact the Procurement Center Representative for your organization and let them know as the original contractor is no longer eligible for small business set asides if they, via their affiliation with the buying company, is no longer a small business.
  11. Is the original contractor a small business? If so, there are additional factors to consider.
  12. The $4M restriction applies to the contract award, but it does not restrict the KO from exceeding that cap after award unless it is an obvious attempt to game that restriction. The regulations themselves only speak to the contract award amount. If the contractor is not an ANC or other tribal entity, then two years after award the KO can modify the contract as high as needed so long at the SBA is notified of the modification no later than the contractor is notified of the modification along with a statement that the modification was not contemplated prior the award of the contract.
  13. awhinton, I believe the reason is that GSA is awarding another option for the contract due to either an extension or a protest ruling. I don't have the slides from the training event yet, (should get them sometime this week), so I can't be more specific.
  14. I just went to a GSA training event yesterday and heard that the 8(a) STARS II contract is just entering its Option Period this year so all contractors will need to recertify their small business status in October per the GSA rep. That recertification is required per 13 CFR § 121.404(g)(3) for long term contracts at the 5th year of the contract and at the start of subsequent option periods.
  15. Freyr, Thanks, I am not sure why the link did not work but that is the correct case. The case itself only dealt with a limited scope but the entire amount of malfeasance that I found went back much farther.
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