GCARL

Mr. Edwards you make an excellent point. I am often taken aback at how frequesntly and how quickly many consultants and even government employed/subsidized small business counselors (including those found at SBA and at PTACs) champion GSA FSS contracting for companies new to government contracting and to start-up companies. While there may be the odd new company or two that may be ready to make that leap straight into a GSA contract, like a high school basketball player to the NBA, many and probably most are not. The expense of compliance and cost of noncompliance can often be too much for a small business to overcome. Too many of these consultants in my experience focus and "sell" how to get a GSA contract without educating and ensuring that their clients know what it takes to comply and sustain success with a GSA contract.

Thank you all for contributing to a very interesting discussion. The issue of Limitations on Subcontracting may well become a hot area for both protests and compliance issues as the "similarly situated" language from NDAA for FY2013 discussed in Footnote 4 of GAO's Sealift, Inc., B-409001 decision winds its way through the process. One would have to sympathize with a contractor who got hit with a Show Cause Notice based on hearsay, innuendo, anecdotal reports or perhaps even "suggestions" from competitors to agency folks. Is it so far fetched to imagine that a frustrated offeror would opt not to protest given the uphill battle they would face challenging an award on the LoS issue, when they could potentially create havoc during contract performance by "blowing the whistle" enough to get contracting officials to make inquiries, especially where the "similarly situated" subcontractors may not be open and obvious to the competitors?