Common Misconceptions: SBA’s Mentor-Protégé Program (Part II – Participation Rules & Limits)

The SBA’s Small Business Mentor-Protégé Program (MPP) is arguably one of the federal government’s most successful undertakings when it comes to supporting our nation’s small business policies, economy, and contracting goals. It fosters the development of small business protégés, allowing many different forms of mentor assistance. It includes opportunity for eligible protégés and their mentors to joint venture (JV) for set-aside contracts—often otherwise off-limits to mentors that don’t qualify for the set-aside status/size standard and/or to protégés incapable of competing for or performing such contracts on their own. MPP JV awards may also incentivize federal government customers—simultaneously getting closer to meeting their set-aside quotas and getting the know-how, qualifications, resources, and personnel of more experienced (typically larger) contractors.

While it’s easy to see why this program enjoys immense popularity amongst small and large businesses alike, confusion consistently shrouds SBA’s MPP, nevertheless (hence the need for a two-parter here). In this article, we’ll skip over the “basics” of SBA’s MPP (which you can read all about here) and instead, jump right into the last few common misconceptions surrounding the program (you can read about the first few in Part I).

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Common Misconceptions: SBA’s Mentor-Protégé Program (Part I – MPP JVs & Affiliation Shield)

The SBA’s Small Business Mentor-Protégé Program (MPP) is arguably one of the federal government’s most successful undertakings when it comes to supporting our nation’s small business policies, economy, and contracting goals. It fosters the development of small business protégés, allowing many different forms of mentor assistance. It includes opportunity for eligible protégés and their mentors to joint venture (JV) for set-aside contracts—often otherwise off-limits to mentors that don’t qualify for the set-aside status/size standard and/or to protégés incapable of competing for or performing such contracts on their own. MPP JV awards may also incentivize federal government customers—simultaneously getting closer to meeting their set-aside quotas and getting the know-how, qualifications, resources, and personnel of more experienced (typically larger) contractors.

While it’s easy to see why this program enjoys immense popularity amongst small and large businesses alike, confusion consistently shrouds SBA’s MPP, nevertheless (hence the need for a two-parter here). In this article, we’ll skip over the “basics” of SBA’s MPP (which you can read all about here) and instead, jump right into the first few common misconceptions surrounding the program (with the rest to follow in Part II).

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The DoD Mentor-Protégé Program’s New Look: Expanded Protégé Eligibility

Many SBA programs and offerings have their origins in other agencies or parts of the federal government. Contractors who do not work with the DoD might be surprised to learn that the DoD’s own Mentor-Protégé Program is in fact the oldest continuously operating mentor-protégé program, dating back to the First Gulf War. Recently, this program received some updates, one of which will greatly expand the pool of eligible proteges. Let’s take a look at these changes in more detail.

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GAO: Solicitation Cannot Require a Protégé Have the Same Experience as its Mentor

SBA regulations prohibit agencies from requiring the same past performance record from both mentor and protégé entities.  The regulations explicitly prohibit this type of requirement.

In a recent GAO decision, it sustained the protest where an agency required all members in a joint venture to submit the same past experience examples in their proposal.

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SBA Processing “All Small” Mentor-Proteges In Eight Days

The SBA is processing the typical “All Small” Mentor-Protege Program application in a lightning-fast eight days.

Speaking at the National 8(a) Association 2017 Small Business Conference, John Klein, the SBA’s Associate General  Counsel for Procurement Law, confirmed that All Small mentor-protege agreements are being processed very quickly.  I was in the audience this morning for Mr. Klein’s comments, which also included many other interesting nuggets on the SBA’s new All Small Mentor-Protege Program.

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