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MDH-1102

Small Business Professional

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I recently became a Small Business Professional for an Army installation.  Before my current position I spent many years as a Contract Specialist as well as a Contracting Officer.  As for my following questions, I am familiar with the "book" answer and all the FAR/DFAR/PGI references,  what I would like to discuss is reality...

1.   As the SB Professional where are my right and left boundaries?  Keeping it as simple as possible,  I feel my job is to ensure the maximum opportunities possible go to small business.  I do this primarily by review and conducting MR.   If the rule of two can be satisfied I push for a SB set-aside (or socioeconomic what ever is applicable).  Is it that simple?  I know there are many factors that go into an Acq. plan (politics, schedule etc ) but is politics and schedule something that the SMP should be concerned with?  If you look at the requirement holistically, yes I should be concerned with those topics.  BUT if I were to "stay in my small business lane" all I should be concerned with is qualified SB contracts and  that we would receive fair and reasonable prices. 

2. What is the spirt of block 18 of the DD 2579?  My take is that as the SMP,  I make RECOMMENDATIONS the Contracting Officer makes DECSIONS.  If there is a disagreement and a "non-concur" is recorded, block 18 allows the Contracting Officer to continue forward.  In my office a "non-concur" is looked at as a personal insult.  I don't understand that and I want the opinion of the group. 

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Re:  Rule of Two.  Please remember that the rule of two is wholly inapplicable to procurements under FAR subpart 8.4 using federal supply schedules and FAR 16.505(b) ordering against multiple-award IDIQ contracts.  So please do not push for set-asides based on the rule of two in these circumstances — in both circumstances, the FAR leaves it entirely to the contracting officer’s discretion and you will want to respect that discretion.  [Note: This assumes the parent multiple-award contracts do not have rule of two language in their ordering instructions — this is permitted, but in my experience very few contracts contain such language.]

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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 Secretary for the SBA's office, usually the SES over the SBA Office of Government Contracting.

If you don't know who your PCR is, check out the SBA website under "Federal Contracting/Procurement Center Representative directory"  Once there you can drill down and find the PCR for your organization if it is listed.  If not, just send a message to the Area Director over the location where your organization is and they will reply with the appropriate PCR contact information.

 

 

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16 hours ago, ji20874 said:

Re:  Rule of Two.  Please remember that the rule of two is wholly inapplicable to procurements under FAR subpart 8.4 using federal supply schedules and FAR 16.505(b) ordering against multiple-award IDIQ contracts.  So please do not push for set-asides based on the rule of two in these circumstances — in both circumstances, the FAR leaves it entirely to the contracting officer’s discretion and you will want to respect that discretion.  [Note: This assumes the parent multiple-award contracts do not have rule of two language in their ordering instructions — this is permitted, but in my experience very few contracts contain such language.]

I agree, and to add a little more...PGI 253.219-70 (b)(2)  clearly states that a DD2579 is not required for actions covered in FAR part 8 

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