NewbieFed Posted September 7, 2022 Report Share Posted September 7, 2022 I'm getting the following FPDS errors when doing a simplified acquisition purchase (under FAR 13 simplified acquisition procedures) of a 29k supply item that was reserved for a small business, but also had a Brand Name restriction in the SAM.gov posting. If "Type of Set Aside" is 'Small Business Set Aside-Total', 'Small Business Set Aside-Partial', 'HBCU or MI Set Aside-Total', 'HBCU or MI Set Aside- Partial', 'Very Small Business Set Aside', 'Emerging Small Business Set Aside' , 'HUBZone Set Aside', 'Service Disabled Veteran Owned Small Business Set Aside', '8(a) Competed', 'Buy Indian', '8(a) with HUBZone', 'Veteran Set Aside', 'Women Owned Small Business', or 'Economically Disadvantaged Women Owned Small Business' then "Extent Competed" must be 'Full and Open Competition after Exclusion of Sources' or 'Competed Under SAP'. If the "Extent Competed" is 'Not Available for Competition', 'Not Competed' or 'Not Competed Under SAP', a valid "Other than Full and Open Competition" must be selected. Is FPDS saying that a small business set aside to allow multiple small businesses to make offers automatically gives the acquisition "competition"? I had a Brand name restriction in my SAM posting, which I thought would still classify it as SAP non-competition under FAR 13? However, if I then select "Competed under SAP" then I can't select Other than Full and Open Competition due additional issues of it not allowing me to select Other Than Full and Open Competition. However, since this is a Brand Name restriction with a JOFOC/Justification, would that count as an Other Than Full and Open? If "Extent Competed" is 'Full and Open Competition' or 'Competed under SAP' then "Other than Full and Open Competition" cannot be selected. If "Other than Full and Open Competition" equals 'SAP Non-Competition' then "Extent Competed" must be 'Not Competed under SAP'. Now I've had COs in the past tell me that FPDS is wonky and sometimes requires nonsensical options, so it's not going to get everything correct. So sometimes, we have to just select different options to remove the FPDS error messages even if the classification isn't quite correct. Is that one of the situations here? Link to comment Share on other sites More sharing options...
Don Mansfield Posted September 8, 2022 Report Share Posted September 8, 2022 What do you mean "reserved for a small business"? Was competition limited to small business concerns, or was it a sole source to a small business concern? Link to comment Share on other sites More sharing options...
GABE Posted September 8, 2022 Report Share Posted September 8, 2022 The days of “revising until the red disappears” are long gone. FAR Part 6 doesn’t apply when utilizing FAR 13, so full and open is non applicable. competed under SAP S/B set-aside Thats assuming the requirement was posted to beta.Sam in regards to GPE requirements stated within FAR 13? Brand Name vs Sole Source requirements have separate justifications and procedures 4 hours ago, NewbieFed said: I'm getting the following FPDS errors when doing a simplified acquisition purchase (under FAR 13 simplified acquisition procedures) of a 29k supply item that was reserved for a small business, but also had a Brand Name restriction in the SAM.gov posting. If "Type of Set Aside" is 'Small Business Set Aside-Total', 'Small Business Set Aside-Partial', 'HBCU or MI Set Aside-Total', 'HBCU or MI Set Aside- Partial', 'Very Small Business Set Aside', 'Emerging Small Business Set Aside' , 'HUBZone Set Aside', 'Service Disabled Veteran Owned Small Business Set Aside', '8(a) Competed', 'Buy Indian', '8(a) with HUBZone', 'Veteran Set Aside', 'Women Owned Small Business', or 'Economically Disadvantaged Women Owned Small Business' then "Extent Competed" must be 'Full and Open Competition after Exclusion of Sources' or 'Competed Under SAP'. If the "Extent Competed" is 'Not Available for Competition', 'Not Competed' or 'Not Competed Under SAP', a valid "Other than Full and Open Competition" must be selected. Is FPDS saying that a small business set aside to allow multiple small businesses to make offers automatically gives the acquisition "competition"? I had a Brand name restriction in my SAM posting, which I thought would still classify it as SAP non-competition under FAR 13? However, if I then select "Competed under SAP" then I can't select Other than Full and Open Competition due additional issues of it not allowing me to select Other Than Full and Open Competition. However, since this is a Brand Name restriction with a JOFOC/Justification, would that count as an Other Than Full and Open? If "Extent Competed" is 'Full and Open Competition' or 'Competed under SAP' then "Other than Full and Open Competition" cannot be selected. If "Other than Full and Open Competition" equals 'SAP Non-Competition' then "Extent Competed" must be 'Not Competed under SAP'. Now I've had COs in the past tell me that FPDS is wonky and sometimes requires nonsensical options, so it's not going to get everything correct. So sometimes, we have to just select different options to remove the FPDS error messages even if the classification isn't quite correct. Is that one of the situations here? Link to comment Share on other sites More sharing options...
NewbieFed Posted September 8, 2022 Author Report Share Posted September 8, 2022 11 hours ago, Don Mansfield said: What do you mean "reserved for a small business"? Was competition limited to small business concerns, or was it a sole source to a small business concern? This was not a sole source. This involved a Limited Source (specifically Brand Name) restricted RFQ posted on SAM.gov that had a small business restriction under a specific NAICS code. Link to comment Share on other sites More sharing options...
NewbieFed Posted September 8, 2022 Author Report Share Posted September 8, 2022 11 hours ago, GABE said: The days of “revising until the red disappears” are long gone. FAR Part 6 doesn’t apply when utilizing FAR 13, so full and open is non applicable. competed under SAP S/B set-aside Thats assuming the requirement was posted to beta.Sam in regards to GPE requirements stated within FAR 13? Brand Name vs Sole Source requirements have separate justifications and procedures Thanks. This was a Brand Name limited RFQ posted to SAM.gov. Your FPDS suggestions are pretty much what I have right now: Extend Competed: Competed under SAP Type of Set Aside: Small Business Set Aside Other Than Full and Open Competition: This is left blank. If I try to mark SAP non-competition or anything else, it immediately gives me errors because it conflicts with the fact there is a small business set aside. So what I'm confused about is even though this uses FAR 13 and not FAR 6, our agency uses Far 13.501-Sole source (including brand name) acquisitions. Our agency considers this type of acquisition to be non-competitive, and considers this to be an "Other Than Full and Open Competition" acquisition that needs a document called Justification for Other Than Full and Open Competition "JOFOC". So even though our agency considers this to be Other Than Full and Open Competition, I'm not supposed to mark this in the FPDS system? Link to comment Share on other sites More sharing options...
formerfed Posted September 8, 2022 Report Share Posted September 8, 2022 You should find your answers here. I quickly looked and think your situation is covered. Read through the instructions and the data dictionary for each element. https://www.fpds.gov/downloads/Manuals/FPDS_User_Manual_V1.5.pdf Link to comment Share on other sites More sharing options...
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