Navigating Equity in Small Business Procurement: Insights and Strategies

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Small Business Works 2022:
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Evaluating Small Business in Source
Selection
 
Lynne
Schneider
Procurement Analyst
Office of Small and
Disadvantaged Business
Utilization, 
General Services
Administration
 
2
 
 
Learning Objectives
 
 
Understand what is a Small Business (SB) Evaluation Factor
Recognize the benefits of using SB Evaluation Factors
Identify the different types of SB Evaluation Factors
Understand when SB Evaluation Factors are used
Know what resources are available for SB Evaluation Factors
 
3
 
 
Evaluation Factors
Evaluation factors and significant subfactors:
Represent key areas of importance in source selection
Support comparison between competing proposals
Award decisions are based on evaluation criteria
At the discretion of agency acquisition officials
 
2
 
 
Encouraging the Use of Small Businesses
 
Per FAR 19.202-1, the Contracting Officer shall:
a)
divide acquisitions of supplies and services
b)
plan acquisitions so more than one small business concern may
perform
c)
ensure delivery schedules are realistic
d)
encourage prime contractors to subcontract with small businesses
e)
provide a copy of the acquisition package to the Small Business
Administration (SBA) Procurement Center Representative (PCR)
 
……what else can COs use to encourage the use of small businesses?
 
 
 
2
 
 
Small Business Evaluation Factors
 
 
A means to increase small business participation
Used in the evaluation process
Gives credit to SBs or socio-economic small businesses during
evaluation; identifies how small businesses will actively
participate in an acquisition; 
or
 gives credit to primes partnering
with SBs
Weighted or pass/fail
Used in any acquisition, including contracts, BPAs or task
orders, even small business set-asides (e.g. HUBZone or
WOSB evaluation factors)
 
 
 
 
 
 
 
 
6
 
 
Why Use Small Business Evaluation
Factors?
 
 
Fulfills public policy objectives
Supports key Administration priority
Helps agencies, including GSA, attain their SB goals
Conveys message that federal agencies take small
business seriously
Benefits the US economy
Contributes to job creation
Improves innovation in the federal marketplace
Statutory requirements
 
 
 
 
 
7
 
 
Types of Small Business Evaluation
Factors
 
 
1.
Small Business and Socio-economic Evaluation Factor
 
1.
Small Business Participation Plan Evaluation Factor
 
1.
Subcontracting Achievement Past Performance Evaluation
Factor
 
 
8
 
 
Small Business and Socio-economic
Evaluation Factor
 
A means to increase the use of small business or socio-
economic small businesses, such as WOSB  or HUBZone
In an unrestricted solicitation may use SB Evaluation Factor
In a SB set-aside could use Socio-economic Evaluation Factor
Task orders, BPA’s, and using GSA Schedules
 
 
 
 
 
 
 
9
 
 
Support for Small Disadvantaged
Businesses
 
Recent OMB Memo, 6/29/22, 
Strategies for Meeting and
Exceeding the Small Disadvantaged Business Goal for Fiscal
Year 2022
Supporting SDB contracting goal increase
Consider giving WOSB or HUBZone higher evaluation credit
when
 
set-asides cannot be used
**Almost 70 percent of WOSBs are also SDB contractors and 67 percent of HUBZone-certified small
businesses are SDBs
 
 
 
 
 
 
 
10
 
 
Socio-economic Evaluation Factor Example
 
Best Value will be used as the basis of the award. Offers will be
reviewed and evaluated using the following four evaluation criteria and
their symbolized relative importance to each other:
 
Technical Capability > Past Performance > Socio-Economic Status >
Price
 
 
Socio-economic Evaluation Factor
Example
 
Preference under the small business socio-economic evaluation
factor will be rated as follows:
High
 preference will be to award to Women-Owned Small
Business (WOSB) prime vendors.
Medium
 preference will be to award to other socio-economic
businesses and small businesses.
Low
 preference will be to award to any other than small
business that demonstrates aggressive small business
participation factors.
 
12
 
 
SB Participation Plan Evaluation Factor
 
 
Used to ensure firms receiving a Government contract will
utilize small businesses in performance of the contract
Emphasis is on prime contractor including small businesses in
proposal development and ultimately subcontracting
Used when acquisition not set-aside for small business
Shall be used if bundling & consolidation applies
 
 
 
 
 
 
 
13
 
 
SB Participation Plan Evaluation Factor Example
 
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Specifically identified small businesses will be listed in the resultant contract.
Small business concerns submitting an offer will receive the maximum score under
this factor without having to submit information under this factor.
 
 
 
 
 
14
 
 
Department of Defense Acquisitions
 
Small Business Participation shall be addressed in source
selection for non-LPTA acquisitions that require a
subcontracting plan
DFARS 215.304, Evaluation factors and significant subfactors
PGI 215.304 - Examples
 
https://www.acq.osd.mil/dpap/dars/dfarspgi/current/
 
 
 
15
 
 
DoD Small Business Participation Plan
Factor Examples*
 
  
(1)
  The extent to which such firms are specifically identified in proposals;
 
(2)
  The extent of commitment to use such firms (for example, enforceable
commitments are to be weighted more heavily than non-enforceable ones);
 
(3)
  The complexity and variety of the work small firms are to perform;
 
(4)
  The realism of the proposal;
 
(5)
  Past performance of the offerors in complying with requirements of the
clauses at FAR 52.219-8, Utilization of Small Business Concerns, and
52.219-9, Small Business Subcontracting Plan; and
 
(6)
  The extent of participation of such firms in terms of the value of the
total acquisition.
* from PGI 215.304
 
 
 
 
16
 
 
DoD SB Participation Plan Template
 
17
 
 
Subcontracting Achievement Past
Performance Evaluation Factor
 
Used to evaluate the extent contractor met its small business
subcontracting goals on past or similar contracts
Can be Pass/fail or weighted
Use when acquisition is not being set-aside for small business
Shall be used when consolidation and bundling applies
 
 
 
 
 
18
 
 
Subcontracting Achievement Past
Performance Evaluation Factor Example
 
 
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19
 
 
Subcontracting Achievement Past
Performance Evaluation Factor Example
 
 
Contractor will receive a “pass” rating for meeting its small business
subcontracting goal and the goals for two socio- economic categories
(SDB, WOSB, VOSB, SDVOSB, HUBZone).  Those who have not
met their overall small business goal will receive a “fail” rating
 
 
20
 
 
Why use a small business evaluation
factor if not required?
 
Industry partners have successfully employed this method
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Doesn’t take long to implement, but can be an effective tool
May facilitate achieving agency small and socioeconomic prime
contracting goals
 
 
 
 
21
 
 
Best Practices
 
If unable to set-aside an acquisition for small
business consider including a small business
evaluation factor
Facilitate achieving agency SB goals via this
method
Leverage Industry Days and Presolicitation
Conferences
Include successful offeror’s small business
participation plan in the resulting contract/BPA or
order
 
 
 
 
22
 
 
Resources
 
 
FAR subpart 15.304
FAR subpart 19.7
GSAM subpart 519.7 (specific to GSA)
DFARS 215.304
PGI Guidance 215.304
DAU website
GSA Multiple Award Schedule, SDB Webpage, FAQs
GSA InSite/OSDBU Webpage (specific to GSA)
 
23
 
 
24
 
Q
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T
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Explore the significance of Small Business Evaluation Factors, Evaluation Factors, and encouraging the use of small businesses in government procurement. Learn how key areas of importance in source selection are represented, how small business participation is encouraged, and the benefits of using Small Business Evaluation Factors.


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  1. U.S. General Services Administration Small Business Works 2022: Navigating Equity in Procurement

  2. Evaluating Small Business in Source Selection Lynne Schneider Procurement Analyst Office of Small and Disadvantaged Business Utilization, General Services Administration 2

  3. Learning Objectives Understand what is a Small Business (SB) Evaluation Factor Recognize the benefits of using SB Evaluation Factors Identify the different types of SB Evaluation Factors Understand when SB Evaluation Factors are used Know what resources are available for SB Evaluation Factors 3

  4. Evaluation Factors Evaluation factors and significant subfactors: Represent key areas of importance in source selection Support comparison between competing proposals Award decisions are based on evaluation criteria At the discretion of agency acquisition officials 2

  5. Encouraging the Use of Small Businesses Per FAR 19.202-1, the Contracting Officer shall: a) divide acquisitions of supplies and services b) plan acquisitions so more than one small business concern may perform c) ensure delivery schedules are realistic d) encourage prime contractors to subcontract with small businesses e) provide a copy of the acquisition package to the Small Business Administration (SBA) Procurement Center Representative (PCR) what else can COs use to encourage the use of small businesses? 2

  6. Small Business Evaluation Factors A means to increase small business participation Used in the evaluation process Gives credit to SBs or socio-economic small businesses during evaluation; identifies how small businesses will actively participate in an acquisition; or gives credit to primes partnering with SBs Weighted or pass/fail Used in any acquisition, including contracts, BPAs or task orders, even small business set-asides (e.g. HUBZone or WOSB evaluation factors) 6

  7. Why Use Small Business Evaluation Factors? Fulfills public policy objectives Supports key Administration priority Helps agencies, including GSA, attain their SB goals Conveys message that federal agencies take small business seriously Benefits the US economy Contributes to job creation Improves innovation in the federal marketplace Statutory requirements 7

  8. Types of Small Business Evaluation Factors 1. Small Business and Socio-economic Evaluation Factor 1. Small Business Participation Plan Evaluation Factor 1. Subcontracting Achievement Past Performance Evaluation Factor 8

  9. Small Business and Socio-economic Evaluation Factor A means to increase the use of small business or socio- economic small businesses, such as WOSB or HUBZone In an unrestricted solicitation may use SB Evaluation Factor In a SB set-aside could use Socio-economic Evaluation Factor Task orders, BPA s, and using GSA Schedules 9

  10. Support for Small Disadvantaged Businesses Recent OMB Memo, 6/29/22, Strategies for Meeting and Exceeding the Small Disadvantaged Business Goal for Fiscal Year 2022 Supporting SDB contracting goal increase Consider giving WOSB or HUBZone higher evaluation credit when set-asides cannot be used **Almost 70 percent of WOSBs are also SDB contractors and 67 percent of HUBZone-certified small businesses are SDBs 10

  11. Socio-economic Evaluation Factor Example Best Value will be used as the basis of the award. Offers will be reviewed and evaluated using the following four evaluation criteria and their symbolized relative importance to each other: Technical Capability > Past Performance > Socio-Economic Status > Price

  12. Socio-economic Evaluation Factor Example Preference under the small business socio-economic evaluation factor will be rated as follows: High preference will be to award to Women-Owned Small Business (WOSB) prime vendors. Medium preference will be to award to other socio-economic businesses and small businesses. Low preference will be to award to any other than small business that demonstrates aggressive small business participation factors. 12

  13. SB Participation Plan Evaluation Factor Used to ensure firms receiving a Government contract will utilize small businesses in performance of the contract Emphasis is on prime contractor including small businesses in proposal development and ultimately subcontracting Used when acquisition not set-aside for small business Shall be used if bundling & consolidation applies 13

  14. SB Participation Plan Evaluation Factor Example Describe how small businesses, including SDBs, WOSBs, VOSBs, SDVOSBs and HUBZone,will play an active role throughout the life of this contract. Include a demonstration of your company s commitment to small businesses under similar contracts. Greater weight will be given to offerors who: Identify specific small businesses meeting at least one socio-economic category Have enforceable commitments with identified small businesses Demonstrate corporate commitment to all types of small businesses, such as through successful partnering under similar contracts or through participation in federal agencies small business mentor-protege programs. Specifically identified small businesses will be listed in the resultant contract. Small business concerns submitting an offer will receive the maximum score under this factor without having to submit information under this factor. 14

  15. Department of Defense Acquisitions Small Business Participation shall be addressed in source selection for non-LPTA acquisitions that require a subcontracting plan DFARS 215.304, Evaluation factors and significant subfactors PGI 215.304 - Examples https://www.acq.osd.mil/dpap/dars/dfarspgi/current/ 15

  16. DoD Small Business Participation Plan Factor Examples* (1) The extent to which such firms are specifically identified in proposals; (2) The extent of commitment to use such firms (for example, enforceable commitments are to be weighted more heavily than non-enforceable ones); (3) The complexity and variety of the work small firms are to perform; (4) The realism of the proposal; (5) Past performance of the offerors in complying with requirements of the clauses at FAR 52.219-8, Utilization of Small Business Concerns, and 52.219-9, Small Business Subcontracting Plan; and (6) The extent of participation of such firms in terms of the value of the total acquisition. * from PGI 215.304 16

  17. DoD SB Participation Plan Template 17

  18. Subcontracting Achievement Past Performance Evaluation Factor Used to evaluate the extent contractor met its small business subcontracting goals on past or similar contracts Can be Pass/fail or weighted Use when acquisition is not being set-aside for small business Shall be used when consolidation and bundling applies 18

  19. Subcontracting Achievement Past Performance Evaluation Factor Example Offerors will be evaluated upon their past achievement in exceeding small business subcontracting goals under past or similar contracts. Greater weight will be given offerors who exceeded all goals for SB, SDB, WOSB, VOSB, SDVOSB and HUBZone. 19

  20. Subcontracting Achievement Past Performance Evaluation Factor Example Contractor will receive a pass rating for meeting its small business subcontracting goal and the goals for two socio- economic categories (SDB, WOSB, VOSB, SDVOSB, HUBZone). Those who have not met their overall small business goal will receive a fail rating 20

  21. Why use a small business evaluation factor if not required? Industry partners have successfully employed this method Sends a strong message to industry that federal agencies are serious about small business Doesn t take long to implement, but can be an effective tool May facilitate achieving agency small and socioeconomic prime contracting goals 21

  22. Best Practices If unable to set-aside an acquisition for small business consider including a small business evaluation factor Facilitate achieving agency SB goals via this method Leverage Industry Days and Presolicitation Conferences Include successful offeror s small business participation plan in the resulting contract/BPA or 22

  23. Resources FAR subpart 15.304 FAR subpart 19.7 GSAM subpart 519.7 (specific to GSA) DFARS 215.304 PGI Guidance 215.304 DAU website GSA Multiple Award Schedule, SDB Webpage, FAQs GSA InSite/OSDBU Webpage (specific to GSA) 23

  24. Questions? 24

  25. Thank You!

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