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Does FAR 19 apply to a FAR 16.505 Task Order RFP off of GSA Alliant SB?

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I am having this debate with an office co-worker. In my opinion, FAR 19 DOES NOT APPLY to a FAR 16.505 Task Order RFP off of GSA Alliant Small Business. So such a task order should not be categorized in our contract file system as a "Total Small Business Set Aside." My co-worker believes FAR 19 does apply, and that it should be coded as a "Total Small Business Set Aside."

I agree that an ordering agency can get "small business preference credit" for awarding a FAR 15.505 task order to a small business off of GSA Alliant SB, but I do not agree that FAR 19 "applies," nor should it be called a "Total Small Business Set Aside."

Who is right?

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FAR 8.405-5 states that FAR 19 does NOT apply to FAR Part 8 GSA FSS orders.

However, my question is about GSA Alliant Small Business, which is not a FAR Part 8 GSA FSS, but rather, it is a GWAC (see FAR 17.501(a)). A GWAC is a different animal than a GSA Schedule order.

In my view, the same concept shoud apply, that an order off a GWAC that happens to only have small business vendors on it is just that, and not a "FAR 19" total small business set aside. I am hoping to find some applicable regulation that says this.

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OK. Sorry. I have reread your question. What are you trying to find out? Are you asking whether an order placed against a multiple award contract under which all the contractor are small businesses can be reported as a total small business set-aside? Or are you asking if FAR Part 19 is applicable to the placement of orders under such contracts?

If you are asking the former, I don't know.

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I am asking if FAR Part 19 is applicable to the placement of orders under the GSA Alliant Small Business GWAC, which only has small business vendors on it.

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Well, at least one subsection applies. See FAR 19.502-4( c).

Actually, your question is way too broad. I mean, I could say that the definitions in FAR 19.001 apply. But I don't think that's the kind of thing you are thinking about.

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I see what you mean about FAR 19.502-4©. It says the contracting officer may, in his or her discretion, set aside an order off of a MAC IDIQ. Ok.

My question is really this: if an ordering agency's contracting officer chooses, in his or her discretion, to NOT set aside the order, but simply does the order off of GSA Alliant SB GWAC under FAR 16.505, is it still proper to call this a "FAR 19 Total Small Business Set Aside"?

I have previously worked on orders off of MAC IDIQs that had a mix of vendors, both large and small. A typical scenario involved a MAC IDIQ that had 20 contractors on it, but only 4 of them were small businesses. If an order was set aside for small businesses only, then only those 4 small business vendors were allowed to compete under fair opportunity for the order.

But for GSA Alliant SB GWAC, 100% of the vendors on it are small vendors. GSA has already done the "total small business set aside" in awarding the Master Contract. So there is no point in setting the order aside only for small businesses, because no matter what, 100% of the offerors will be small business.

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Whoa! Are you asking whether the CO must consider a small business set aside for a new contract as opposed to placing an order against a GWACs?

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