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Don Mansfield

Squaring DFARS 219.201(d)(10) and the DD Form 2579

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FAR 19.201(d)(10) requires the Director of the DoD Office of Small Business Programs to--

Make recommendations in accordance with agency procedures as to whether a particular acquisition should be awarded under subpart 19.5 as a small business set-aside, under subpart 19.8 as a section 8(a) award, under subpart19.13 as a HUBZone set-aside, under subpart 19.14 as a service-disabled veteran-owned small business set-aside, or under subpart 19.15 as a set-aside for economically disadvantaged women-owned small business (EDWOSB) concerns or women-owned small business (WOSB) concerns eligible under the WOSB Program.

DoD implementation of this requirement is at DFARS 219.201(d)(10), which states:

Contracting activity small business specialists perform this function by—

(A) Reviewing and making recommendations for all acquisitions (including orders placed against Federal Supply Schedule contracts) over $10,000, except those under the simplified acquisition threshold that are totally set aside for small business concerns in accordance with FAR 19.502-2. Follow the procedures at PGI 219.201(d)(10) regarding such reviews.

(B) Making the review before issuance of the solicitation or contract modification and documenting it on DD Form 2579, Small Business Coordination Record; and

© Referring recommendations that have been rejected by the contracting officer to the Small Business Administration (SBA) procurement center representative. If an SBA procurement center representative is not assigned, see FAR 19.402(a).

So the small business specialist makes a recommendation to the contracting officer, which the CO can accept or reject. If the CO rejects it, the small business specialist refers the matter to the SBA.

Now, look at the DD Form 2579. Block 9 is titled "Recommendation." In Block 17, the CO documents their concurrence with or rejection of the recommendation. Additionally, the block also has a space where the CO can make a recommendation, presumably if they have rejected the initial recommendation. In Block 18, the small business specialist can then concur or appeal with something, presumably the recommendation of the contracting officer.

Question: Who should complete Block 9?

I don't care what your practice has been, just read the reg, look at the form, and make sense of them. (If you say "the buyer", provide a citation to support your answer).

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Don, see here: https://dap.dau.mil/aap/pages/qdetails.aspx?cgiSubjectAreaID=31&cgiQuestionID=114586

Block 9. Recommendations. Enter the Contracting Officer’s recommendation whether the acquisition should be pursued under one of the small business preference programs for SB/SDB business, etc. Recommendation must consider the DoD set-aside program order of precedence in DFARS 219.504. Block 9a pertains only to Section 8(a) acquisitions. If all recommendations are “No”, an explanation must be provided in Block 14.

BTW, a propsed, new 2579 was circulated for comment this past summer. The final, new 2579 should be issued very soon.

In the draft, new form 2579 the recommendation is made at block 10:

10. Recommendation Check the recommended type of procurement. Check all that apply, e.g., a small business set-aside could also be a MAC. If Block 10a. is checked and “Partial” is checked, then the percentage estimate is calculated by considering market research, acquisition history, and the independent government estimate of services or supplies suitable for a small business set-aside. Attach the proposed acquisition strategy/plan. For J&As >$20 million (blocks 10b., c., and d.), attach J&A. If Block 10j. is checked, then the acquisition strategy/plan must indicate contract number, if any portion of the requirement will be set aside for small business, if reserves will be used, and if orders may be set aside for small business (ref. FAR Subpart 19.502-4).

While this does not identify the signer, the Instructions at the top of page 3 of the draft, new 2579 said:

All DoD activities shall use DD Form 2579 in accordance with DFARS 219.201(d)(10). The Contracting Officer with execution authority commensurate with the estimated cost of the subject acquisition is responsible for preparing the form and coordinating all small business strategy decisions or recommendations on a particular acquisition with the local Small Business Professional. After signing the completed form, the Contracting Officer will submit it to the Small Business Professional and a Small Business Administration Procurement Center Representative (PCR) who will review and sign it before synopsis. Utilize the process in FAR 19.505 to resolve any failure to agree. The contract file shall retain a copy of the signed form with all attachments.

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I don't know the origin of the DD 2579 instructions in the CON 260B Student Guide (a course I actually teach), but I know they are not official. I've asked the folks that manage the DoD Forms Program to send me the official instructions for the form, but never received a response.

This came up because I was looking for something in the DFARS or PGI that said that a contracting officer is responsible for preparing a DD Form 2579. The only place that I could find that mentioned the DD Form 2579 is DFARS 219.201(d)(10)( B ), which requires the small business specialist to document their review on the form. I think the DFARS should explicitly say that the contracting officer is required to prepare a DD Form 2579 for each acquisition over $10,000.

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