GSA Schedules and FAR 19.000(a)(3)

[Gns]

I'm not comfortable with the wording at FAR 19.000(a)(3) and would appreciate some help. I've always been under the impression that I cannot make a directed 8(a) buy using GSA Schedules. However, looking at the current wording in FAR, I'm not as comfortable with my previous interpretation.

FAR 8.405-5, Small business, is clear to me. It indicates I'm allowed to set-aside orders for any of the small business concerns identified in 19.000(a)(3).

8.405-5 Small business.

(a) Although the preference programs of part 19 are not mandatory in this subpart, in accordance with

section 1331 of Public Law 111-240 (15 U.S.C. 644®)—

(1) Ordering activity contracting officers may, at their discretion—

(i) Set aside orders for any of the small business concerns identified in 19.000(a)(3); and

FAR 19.000(a)(3) goes on to state:

19.000 Scope of part.

(a) (3) Setting acquisitions aside for exclusive competitive participation by small business, 8(a) business development participants, HUBZone small business concerns, service-disabled veteran-owned small business concerns, and economically disadvantaged women-owned small business concerns and women-owned small business concerns eligible under the Women-Owned Small Business Program;

What I'm having difficulty with is:

(1) the placement of the word "competitive". Are they strictly speaking to competitive participation by small business, or competitive participation by 8(a) businesses, competitive HUBZones, etc.

(2) FAR 8.405-5 states I can set an order aside for any of the small business "concerns" listed in 19.000(a)(3). 8(a)'s are one of the various "concerns" listed.

I probably took a long time to get to my question. But, can you do a directed 8(a) through the GSA Schedules program? Any help appreciated.