Category Archives: Uncategorized

Thank You, Navy Gold Coast!

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I am back in the Midwest after a great trip to San Diego for the 2018 Department of the Navy Gold Coast Small Business Procurement Event.  I was part of a PTAC-sponsored legal panel on small business issues, and enjoyed speaking with contractors, government representatives, and others on the trade show floor.

Thank you very much to the San Diego chapter of the National Defense Industrial Association for sponsoring this fantastic event and inviting me to speak.  And a big thank you to the many contractors who attended the session and asked great questions.

If you haven’t had the pleasure of attending Gold Coast, I strongly encourage you to put it on your radar screen for 2019.  It’s hard to beat a great conference in a great city.  As for me, I’ll be hitting the road again soon: I will be in Norman, Oklahoma on August 21 and 22 for the annual Indian Country Business Summit.  Hope to see you there!

All Small Mentor-Protege: SBA Confirms “Two Per Lifetime” Limit

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A small business “can have no more than two [SBA] mentors over the life of the business,” according to the SBA’s All Small Mentor-Protege Program website.

The SBA’s clarification of the lifetime limit provides important guidance for proteges, especially because the SBA’s mentor-protege regulations aren’t exactly crystal clear when it comes to this point.  The SBA’s limit ensures that small businesses don’t become permanent proteges–but is “two per lifetime” the best way to carry out that policy?

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SBA Small Business Size and Affiliation Rules: My New Handbook is Now Available

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I am excited to announce the publication of SBA Small Business Size and Affiliation Rules, the second volume in our series of new government contracting guides called “Koprince Law LLC GovCon Handbooks.”

Written in plain English and packed with easy-to-understand examples, this GovCon Handbook demystifies the SBA’s rules regarding small business status for government contracts.

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SmallGovCon Week in Review: July 2–6, 2018

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We hope you had a wonderful Fourth of July. Next week promises to be busy, with vacations ending and preparations for the 4th quarter rush. In the meantime, let’s dive into this week’s edition of the SmallGovCon Week in Review!

This week, we highlight IT draft requests from the DOT, an update to the DHS EAGLE II program, a proposed amendment to the DFARS, and more.

Have a great weekend!

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Limitations on Subcontracting: FAR Revisions May Be Delayed

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At least a couple times a month, I’m asked when the FAR’s limitations on subcontracting provisions will be updated to correspond with SBA regulations adopted in 2016, and underlying statutory changes adopted way back in the 2013 National Defense Authorization Act.

Well, now it seems that the FAR updates may take longer than I’d hoped.  In its most recent “Open Cases” update, the FAR Council says that it’s made a switch in the procedure that will be used to implement the changes to the limitations on subcontracting–and that switch will likely delay the implementation of those changes by several months.

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Let’s Replace SBA Small Business Goaling Grades with Participation Trophies

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For Fiscal Year 2017, SBA’s small business goaling scorecard awarded 21 agencies grades of “A+” or “A” for their small business contracting and subcontracting.  Two agencies received a “B” and a single, lonely agency brought up the rear with a “C.”  Not one agency received a grade below “C,” even agencies that missed most of their small business goals.

It was a “record breaking” performance, to hear SBA tell it.  But these inflated grades do a disservice to the public and government alike.  So long as almost everyone is going to get a top grade anyway, I say we just replace next year’s SBA goaling grades with agency participation trophies.

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Hack Response: Notarized Letters Now Required for SAM.gov

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Because of a recent cyber attack on the System for Award Management, the Federal Service Desk is requiring new contractors to submit a signed notarized letter in order to be registered. Later this month, existing registrants seeking to update or renew profiles will have to do the same.

This move comes after the General Services Administration acknowledged on March 22 that the inspector general is looking into a hack of the SAM.gov database, in which the hackers changed the banking information for “a limited number” of contractors.

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