ANC/8a and SB set aside contracts

[lsr]

I know that Alaska Native Corporations (ANCs) can enter the 8a program regardless of their size, and are exempt from some of the 8a limitations (such as the $4M limit on 8a sole source contracts) and can keep recertifying to stay in the program. However, in ORCA the ANCs show whether they are considered small under certain NAICS codes. Can an ANC enrolled in 8a compete for a small business set aside competitive procurement even if the ANC is considered large under the procurement's NAICs code?

SBA guidance in general says that small businesses must qualify as small under the procurement's NAICS code if they bid as the prime contractor. I am unsure, though, if the special rules for ANCs under 8a allow them to compete for SB set-aside procurements even if they are large in that NAICS code. For example, the ANC certifies as small under NAICS 541712 (under 500 employees) but large under NAICS 541690 (over $7M in revenue). A small business set-aside procurement comes out under NAICS 541690. Is the ANC eligible to bid as small because they are in the 8a program?

[brian]

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In an SBSA, the offeror has to certify that they are small in that NAICS code.

In your example, no, the ANC would not be considered small.

Maybe I'm picking nits, but a large ANC doesn't get to join the 8(a) set-aside program.

They have to create a daughter corp that is small.

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