Mickey1968

I have a VISN wide requirement that involves 11 facilities. Here is the back story, before the merger of VISN X and VISN Y in 2016, these same services were being provided under two separate contracts. Now that both VISNs have merged, the contracts are expiring. They are both for the SAME services, nothing has been added. However, I am making it one contract instead of 11 separate contracts. That would be too administratively burdensome to have that many contracts. Market research was conducted, and small businesses showed an interest in submitting a proposal for this combined acquisition. Respondents were asked 21 questions to ensure that the small business concerns were capable of performing these services. The sources sought notice clearly stated that this was a VISN contract consisting of all facilities. The solicitation was set aside for small business. When the solicitation closed, no proposals were received from any small business concerns. Now, I need to go full and open and SBA is denying citing unjustified bundling and unjustified consolidation. I've written a justification as to why this procurement needed to be consolidated. SBA is stating, If it is determined that it is also bundling (see definition at FAR 2.101), then the bundling would need to be determined as necessary and justified pursuant to FAR 7.107-3. They also stated, this would also be substantial bundling (FAR 7.107-4) based on the total dollar value ($9.3mil). Substantial bundling has requirements which are in addition to the documentation requirements for bundling. How do I write a justification paragraph in accordance with FAR 7.107-3 & FAR 7.107-4. I'm new at this and haven't done this before. This entire procurement is being help up over this justification. I'm STRESSED!!! please help. Thanks