February 13, 2012 at 2:33 am #152987
My colleague over at the American Small Business Coalition, Guy Timberlake, proposed an approach of ensuring small business goals are really being met though a policy of “follow the money”:
…What I’m referring to is including small business subcontracting as line items on the contracts awarded to prime contractors with a dollar amount (not an award fee) associated with each CLIN. The concept is pretty straightforward. Don’t deliver, don’t get paid. Just as in the case of other CLIN’s for goods and services, these deliverables would be agreed upon by the prime and the government agency. In this case it would be a blend of what small business participation the agency expects, and what the prime signs up for. The Small Business Subcontracting Plan would effectively represent one or more CLIN’s on the resulting contract…
I am all for mechanisms to ensure that small businesses get a fair shake in the federal contracting arena (being one myself). However, I believe mechanisms already exist. What is needed is that one word that sums up the missing link in many of these issues: ACCOUNTABILITY.
I have seen contracts structured such that parts of it (i.e. sections of a SOW are to be done by small businesses, and thus the CLIN would be integrated with the small business subcontracting plan required per Federal Acquisition Regulation Part 19). However, it is the enforcement that I rarely see.
What happens to a large business that submits a compliant subcontracting plan to get in the door, then does not actually follow through in percent work and dollars to be performed by small businesses? My experience is very little.
Isn’t this what performance-based contracting, or incentives for that matter, is all about? There should be metrics, measures, and of course, the surveillance and enforcement (e.g. accountability) for complying with these plans, or lack thereof.
- How are contracting organizations ensuring compliance and enforcement with small business subcontracting plans?
- What recourse to small businesses have in your federal organizations?
- What enforcement mechanisms exist, or need to be constructed, to ensure that small business goals are not only achieved, but actually represent the true work being done by small businesses?
February 13, 2012 at 4:32 pm #152991
Peter G. TuttleParticipant
Hi Jaime. Great timing. Last week I was talking with a very senior Federal acquisition official and he had the best suggestion I’ve heard of yet – Make the agency/department small business goals applicable to a number of corporate-level executives, not simply those executives in the procurement rganization.
If the “tone” from the top is that small business is important, more than just the procurement guys will be looking for ways to increase the percentage of small business acquisitions. Achieving small business goals will be easier if executives from program management and requiring organizations are also held accountable for the success of the program within the agency/department. In a way this makes perfect sense, since it is National socio-economic goal that transcends individual organization goals (at least theoretically). Hopefully, you’ll get some lively debate on this one. Cheers. Pete
February 13, 2012 at 4:51 pm #152989
@Pete – Socioeconomic goals are in fact the program office responsibility, although they do not seem to be held accountable. Instead, the procurement organization is held responsible.
Program offices are responsible for market research, and ensuring opportunities exist for small business participation through effective requirements development (e.g. preventing bundling), and working with the procurement organization to understand and meet these small business goals. Further, small business contracting should be job one for everyone in the organization, so again it starts with the program office to qualify the need for socioeconomic set-asides, and working hand-in-hand with the procurement office on the acquisition strategy for effective socioeconomic contract execution.
Nonetheless, accountability has been flipped on its head, small business advocates and OSBDUs have little to no teeth, and the SBA is overwhelmed. The result is little accountability and enforcement.
I hope to get some discussion around offices that are enforcing these goals, and how they are achieving them. best practices and lessons learned can go a long way if they get communicated, but they first must be shared!
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