GSA strongly supports the participation of small business concerns in the GSA Schedules program. Small Business Administration (SBA) policy allows agencies to include in their procurement base and goals the dollar value of orders expected to be placed against Schedule contracts, and to report actual Schedule procurements as accomplishments against these goals. Currently, orders to Schedule 8(a) contractors do not receive 8(a) credit. However, since 8(a) contractors are, by definition, small disadvantaged businesses, ordering activities may count awards to such companies against their small business goals.
“Set-asides,” as described in FAR 8.405-5, are now allowed under the GSA Schedules program at the discretion of the ordering activity’s Contracting Officer. Ordering activities may also consider socioeconomic status when identifying contractor(s) for consideration or competition for award of an order or BPA. At a minimum, ordering activities should consider, if available, at least one small business, veteran-owned small business, service-disabled veteran-owned small business, HUBZone small business, women-owned small business, economically disadvantaged women-owned small business, or small disadvantaged business Schedule contractor(s).
Set-asides at the Schedule Level
While set-asides are allowed at the order level under a GSA Schedule, following procedures in FAR 8.405-5, GSA has also set aside some Schedules and SINs at the contract level under FAR Part 19. Visit www.gsaelibrary.gsa.gov and search using the term "set aside" for a complete listing of Schedules and SINs that have been set aside.
Schedule contractors’ catalogs/price lists, GSA Advantage!® and GSA eLibrary contain information on a broad array of supplies and services offered by small business concerns. This information should be used as a tool to assist agencies in providing the maximum practicable opportunities for small business concerns, including set-asides, in order to meet or exceed established small business goals. The information should also be used as a tool to assist in identifying small business, veteran-owned small business, service-disabled veteran-owned small business, HUBZone small business, women-owned small business, economically disadvantaged women-owned small business, and small disadvantaged business Schedule contractors when making a best value determination.
For orders exceeding the micro-purchase threshold, ordering activities should give preference to the items of small business concerns whenever two or more items at the same delivered price will satisfy the requirement (refer to FAR 8.405-5). In accordance with FAR 8.405-5(a), ordering activities should rely on the small business representations made by Schedule contractors at the contract level.
It is important to remember that socioeconomic status can be utilized as a primary evaluation factor in source selection.
Ordering activities may count orders with small business firms toward their socioeconomic goals. Small Business Schedule contractors are identified in GSA eLibrary and GSA Advantage!® by socioeconomic indicators (e.g., s=small business).
Small Business Process
GSA is committed to supporting small business and helping agencies achieve their small business goals. The following information will assist the federal buyer in understanding how to use Schedules to enhance small business utilization in the procurement process.
Conduct market research
Ordering activities should utilize GSA Advantage!® and GSA eLibrary to identify small businesses capable of meeting the requirement. Through GSA Advantage!®, ordering activities can find all contractors who provide the supply/product required and view the socioeconomic status of each contractor. Through GSA eLibrary, ordering activities can find all contractors under the Special Item Number (SIN) associated with the required supply or service; ordering activities can then go one step further and filter the list of contractors by any specific socioeconomic category desired.
If a search on GSA Advantage!® and GSA eLibrary does not result in any possible small business sources, ordering activities may also consider issuing a Request for Information (RFI) on eBuy to determine the capabilities of small businesses in the relevant SINs and to identify small businesses capable of doing the work. An RFI is especially helpful in determining whether there are small businesses capable of doing the work under a set-aside, where there is a limitation on subcontracting and the nonmanufacturer rule applies.
After conducting market research, ordering activities should be able to answer the question, “Is a small business capable of doing the work?”
A Small Business is Capable of Doing the Work in Its Entirety
If the ordering activity has determined that a small business can meet the whole requirement alone, it has two options:
- In the acquisition of supplies or services not requiring a statement of work, and below the simplified acquisition threshold, ordering activities simply have to review the catalog or price list (available on GSA Advantage!® and GSA eLibrary) of at least three Schedule contractors who are small businesses and place an order with the Schedule contractor that represents the best value.
- In the acquisition of services requiring a statement of work and below the simplified acquisition threshold, ordering activities can designate socioeconomic status as a primary evaluation factor in the Request for Quote (RFQ). For additional guidance on how to use socioeconomic status as an evaluation factor, see the sample RFQ language posted on www.gsa.gov/schedulesandsbgoals.
- If there are enough firms that can provide the solutions agencies seek, set aside the requirement for small business or one of the small business subcatagories, as defined in FAR Part 19.000(a)(3). This is not mandatory; it is the Contracting Officer’s discretion to use a set-aside, or not. If the Schedule contract does not include them, the RFQ issued must include the requisite clauses and language regarding the set-aside.
A Small Business is Capable of Only Doing Part of the Work on Its Own
If market research reveals that there is no small business that can meet the requirement as a whole but there are small businesses that can each cover portions of the entire requirement, ordering activities can designate socioeconomic status as a primary evaluation factor and also encourage Contractor Teaming Arrangements (CTAs) in the RFQ. The RFQ can then be posted on eBuy which will result in all Schedule contractors awarded the relevant SIN(s) to be able to view the document. While posting on eBuy will result in the RFQ being viewable by large businesses awarded the relevant SIN(s), designation of socioeconomic status as an evaluation factor and the CTA language in the RFQ will prompt them to find a small business (or businesses) to partner with in responding to the requirement. Posting on eBuy will also ensure that a sufficient number of small businesses (i.e., all those awarded the relevant SIN(s)) have access to the RFQ so that there is a greater probability of receiving responses from CTAs made up solely between small businesses. For sample RFQ language on evaluating CTAs for the socioeconomic status factor, visit www.gsa.gov/schedulesandsbgoals.
A Small Business is Not Capable of Doing Any Part of the Work
If market research reveals that the requirement can only be met by an “other than small business,” ordering activities can still utilize small business by designating subcontracting to small businesses as a primary evaluation factor. Ordering activities can then post the RFQ to eBuy.
Evaluate the Quotes
In any situation, quotes must always be evaluated in accordance with the evaluation factors listed in the RFQ.
Report Contractor Performance in CPARS
Recent rulings require ordering activities to report past performance and other responsibility-related determinations into the Contractor Performance Assessment Reporting System (CPARS).
Regardless of whether the BPA/task order was placed with a small business, a CTA, or an “other than small business,” ordering activities should report past performance for the contractor in CPARS for all orders, but must report past performance for orders exceeding the SAT. Positive past performance will assist the small businesses with being awarded BPAs/orders in the future.