The 20 Commandments of Success as a Subcontractor

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Tonya Buckner of BucknerMT Management & Technology, Inc. is the Chief Executive Officer at Buckner Management & Technology, BucknerMT and TAPE are teaming together to find new business for our two companies.

I asked Tonya to contribute some thoughts about life as a subcontractor:

Last week at a BrewtonMos Procurement Readiness luncheon, TAPE CEO/President Louisa Jaffe spoke on a panel and shared the following pearls of wisdom:

  • Be passionate
  • Have a clear vision and mission
  • Clearly define your brand early
  • Learn about contracting
  • Master the proposal development process
  • Start with vision

I just finished reading Three Feet from Gold by Sharon Lechter, a book about turning your obstacles into opportunities. The premise of the book is in line with what Mrs. Jaffe shared today:

  • Have passion for what you do
  • Find your own personal success formula
  • Choose good counsel, and above all:
  • Never give up

Although the above relates to entrepreneurs in general, I believe it is that entrepreneurship spirit that also allows you to be a successful subcontractor. For specific lessons about being a subcontractor, I’ll close with the “BucknerMT 20 Commandments,” which is a list we created based on our own experience as a subcontractor. We use them as internal guiding principles.  

  1. Always remember when you are working with the client, you represent the prime so do everything in your power to make them shine.
  2. Be comfortable with being uncomfortable. You have to stretch yourself past your comfort zone.
  3. Constantly look for value you can contribute to your teaming partners (e.g., participate in proposal efforts and/or bring new business opportunities).
  4. While subcontracting, strategically position yourself for prime opportunities.
  5. Focus on building your corporate reputation while building the past performance.
  6. Focus on providing high quality business solutions.
  7. Understand the culture, clients, leadership and systems.
  8. Be committed to excellence.
  9. Strive to foster and maintain positive relationships with each and every client (both internal and external).
  10. Equip yourself to succeed in business (develop/maintain a growth plan).
  11. Consistently seek innovative ways to assist your client in meeting goal.
  12. Make continual education/training a priority.
  13. Never compromise your principles.
  14. Set a corporate financial base in which you want to maintain. Try not to put all your eggs in one basket; the work is NOT guaranteed!
  15. Listen!
  16. Be flexible.
  17. Be ready.
  18. Be reliable.
  19. Be responsive.    
  20. Be patient.

BucknerMT Management & Technology, Inc. (BucknerMT, Inc.) is a verified service-disabled veteran-owned small business (SDVOSB) and woman-owned small business (WOSB). From service strategy to continual service improvement, BucknerMT have deep domain knowledge and experience in information technology and supply chain management.

Since 2007, BucknerMT have supported the Department of Defense (DoD) and the Defense Information Systems Agency (DISA) by providing services that include engineering, integrating, and sustaining critical military platforms and systems.


What’s Stopping Women From Becoming Entrepreneurs?

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This is a guest post by Staci Redmon of SAMS.

Women entrepreneurs own 10.6 million businesses in the U.S., and employ 19.1 million people, who account for $2.5 trillion in sales. But according to the Kauffman Foundation, women represent only 35 percent of startup business owners, even though they represent about 46 percent of the workforce and more than 50 percent of college students.

So why aren’t there more women entrepreneurs?

One study, conducted by the University of North Carolina and the Wharton School at the University of Pennsylvania (and reported by National Public Radio) looked at 90,000 entrepreneurial projects launched on the crowdfunding website, Kickstarter. The study found that men are much more likely to be overconfident than women. When their project failed, they were much more likely to keep trying, while women tended to give up. Also, when women succeeded, they were more likely to feel that they just got lucky, while men feel that they are “geniuses.”

There is help for women entrepreneurs just starting out. The SBA set up its 8(a) Business Development Program to assist economically-disadvantaged women-owned small businesses (EDWOSBs) to compete for federal contracts in industries where women-owned small businesses are underrepresented. Women and minority-owned businesses can get access to specialized business training, counseling, marketing assistance, and high-level executive development. The SBA also offers guaranteed loans and bonding assistance for being involved in the program. SAMS has benefited from its SBA designation, and has also become part of the Mentor-Protégé Program which helps other women entrepreneurs through one-on-one mentorship.

Building a business is not easy, and many women cite the same characteristics as helping them to achieve their dream.

Gayle King of CBS news talks about persistence as a trait helped propel her to achieve her goal. She advises would-be entrepreneurs to “surround yourself with people that are better than you, because it forces you to up your game. Most importantly, never take no for an answer.”

When Staci Redmon founded SAMS, it was important to her to develop core values, which still remain at the heart of the company. These are commitment to employees, commitment to the client, and commitment to the community.

Staci started SAMS out of sheer frustration. As a veteran and a civil servant, she watched as vital equipment for our warfighters was denied funding. She used her determination and commitment to service members to fuel her drive to create an organization with the vision to measure impact not by the bottom line, but by the difference it could make. Since its founding, SAMS has won numerous awards and has been hailed repeatedly as one of the fastest growing companies in Virginia.

Another entrepreneur, JK Rowling, also relied on persistence to overcome adversity. Her literary agency sent the book to 12 different publishers before it was accepted. Rowling says, “I stopped pretending to myself that I was anything other than what I was and began to direct all my energy into the only work that mattered to me. I was set free.”

As women entrepreneurs continue to pursue their dreams, the path to success, while never easy, becomes clearer and less uncertain by following in the footsteps of those who came before.

You can find more about SAMS and Staci’s 2020 Vision for the Future on our website http://www.getsamsnow.com.

This article originally appeared at http://getsamsnow.com/blog-post/whats-preventing-women-becoming-entrepreneurs/ and was adapted and reprinted with permission.


WOSBs and The Rule of Two

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After publishing my article about sole source contracts for women-owned small businesses, I received the following comment on LinkedIn:

“Mr. Jaffe, isn’t it still very difficult for EDWOSB firms that provide services, i.e., program and project management, to receive sole source contracts due to the Rule of Two? The 8(a) program is different in that they can sole source to firms even if there are 100 other 8(a)s that can provide that service, whereas if a client wants a particular firm but there are others that provide the service then they can do a set aside, but can’t directly award a sole source contract to that EDWOSB.

Am I correct in this, or is the program changing so that the Rule of Two will not be a factor and EDWOSB’s are following the same sole source rules as 8(a)?”

When I followed up with Matthew to find out more about what was behind his question, he told me:

Bugbee Consulting is an EDWOSB for years now and we were excited about the changes to the program, until they were implemented and the rules were more similar to other programs rather than the 8(a). Essentially, no contracting office will attempt a WOSB sole source to a service-oriented firm like Bugbee Consulting due to the Rule of Two.”

My team and I dug a little deeper, but unfortunately we didn’t have any better news for Matthew. Indeed, the Rule of Two applies to the WOSB program, as it does to all other set-aside programs. WOSB sole source requires you follow the same rules that you do for service-disabled veteran-owned small business or HUBZone sole source procurements.

Contracting officers can accept TPC (third-party contracting) when verifying an offeror’s eligibility for WOSB or EDWOSB set-aside contracts or sole source awards. As well, contracting officers can accept a WOSB’s or EDWOSB’s self-certification, as long as the contracting officer verifies that the required documentation has been uploaded to the WOSB Repository.

Contracting Officers’ roles and responsibilities in connection with the WOSB Program are discussed in FAR 19.15. If you have more questions, I’d suggest you contact your local Procurement Center Representative (PCR) for guidance on WOSB Program requirements.


Small Business Jobs Act of 2010 – Defining Reduced and Late Payments

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Effective January 19, 2017, DoD, GSA, and NASA issued a final rule amending the Federal Acquisition Regulation (FAR) to implement a section of the Small Business Jobs Act of 2010. According to the Federal Register, “this statute requires contractors to notify the contracting officer, in writing, if the contractor pays a reduced price to a small business subcontractor or if the contractor’s payment to a small business subcontractor is more than 90 days past due.”

The new FAR clause 52.242-5 defines a reduced payment as a payment that is for less than the amount agreed upon in a subcontract in accordance with its terms and conditions, for supplies and services for which the Government has paid the prime contractor.

An untimely payment is defined as one that is more than 90 days past due under the terms and conditions of a subcontract, for supplies and services for which the Government has paid the prime contractor.

As I discussed in a previous post, these incidents then get reported into a system called FAPIIS, and a history of delayed payments in FAPIIS will affect a prime’s CPARS rating (Contractor Performance Assessment Reporting System), which could affect eligibility for future contracts.

These new clearer definitions give this ruling some teeth. Since it’s possible to get dinged in a permanent accountable way that will be noticeable to prospective customers, it’s advantageous for primes to pay on time.


2017 NDAA Changes to Mid-Tier Small Business Contracting

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As I wrote earlier on this blog, “Business growth is something that should be celebrated, yet if you’re a small business whose customer is the federal government, your growth can have a noticeable downside.” Namely, being too big to qualify for small business set-asides.

If your business falls into the mid-tier category of being too big to be eligible for set-asides but too small to compete with industry giants, here are the most important changes from the 2017 NDAA (click the links to learn more about each item):

  • Gives certain small subcontractors a new tool to request past performance ratings from the government. If the pilot program works as intended, it may ultimately improve those subcontractors’ competitiveness for prime contract bids, for which a documented history of past performance is often critical (learn more).
  • Will require the GAO to issue a report about the number and types of contracts the Department of Defense awarded to minority-owned and women-owned businesses during fiscal years 2010 to 2015. The GAO will be required to submit its report within one year of the statute’s enactment (learn more).
  • Designed to help ensure that large prime contractors comply with the Small Business Act’s “good faith” requirement to meet their small business subcontracting goals (learn more).
  • Establishes a new prototyping pilot program for small businesses and nontraditional defense contractors to develop new and innovative technologies (learn more).
  • Will extend the life of the Small Business Innovation Research and Small Business Technology Transfer programs (learn more).

We’ll keep digging into these topics and what they mean for your federal contracting success. Stay tuned!


Are You Wired to Win?

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In a webinar called “Wired! How can I do that?” Judy Bradt of Summit Insight painted a picture I’m sure many of you would find familiar. You saw something on www.fbo.gov that looked like the perfect opportunity – work you could do, that matched your experience, yet somebody else won the job.

How? They got the opportunity wired for them.

It was such a great topic I asked her to tell us more.

I’ve heard you say that proposals require “perfection on every page” – why?

Contracting officers can only consider offers that are full responsive. That means not only answering every question, but providing the correct information in the format and order required, to exactly the right person, by the right time, to the right place. Any ONE failure can disqualify your entire effort – often, an investment of THOUSANDS of dollars and weeks of time. That’s right: the contracting officer won’t even be able to look at it, no matter how great your price, and how perfect your experience.

Why is it important for a contractor to have a bid/no bid checklist in place?

It comes down to win rate. In a perfect world, you’d win every time. If you can’t win every time, you want to win as often as possible. Your company’s bid/no-bid checklist sums up the signs that you have a high probability of winning. An opportunity with all the winning signs is your top priority to bid. The income you get from the winning bid also has to cover the cost of all the losing bids. The fewer losers you write, the more money you get to keep!

What are three things our competitors are doing to win?

  1. They’re building relationships with all the decision makers inside the account.
  2. They’re only bidding projects where they have past performance that strongly resembles the kind of work the buyer needs done.
  3. They’ve been in there talking to the buying team a long time before the requirement hits the street, shaping the buyer’s idea of them as a low-risk supplier.

You have a 10-step scorecard to identify what a team needs to win more federal business. Can my readers get a copy?

The scorecard is part of the Government Contracts Made Easier: The Strategy Workbook. This is a 64-page fillable PDF that you can use and update again and again, and share within your company. The list price is $69.95, but if you contact me, I’ll send it to you with my compliments.

Thanks, Judy! To hear more of Judy’s excellent tips and strategies, join her for a complimentary webinar, Top Tactics to Meet Federal Buyers. It’s coming up soon on April 18th, so be sure to register now.


Federal Contractors Can Now Protest Civilian Task Orders Over $10 Million

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We’ve talked before about protests, and when and how to do them, risk factors and warnings, etc., as well as some of the issues and processes. The perception is that there are a lot of protests, and that if YOUR contract award is protested, that’s clearly one too many…

One area that has expanded lately is the use of Multiple-Award (MA) IDIQ contracts, and the task orders underneath them have often been quite large. Originally, you could only protest contracts, but the task orders were immune to protests. Then, the GAO Civilian Task and Delivery Order Protest Authority Act of 2016 (H.R. 5995) became law on December 14, 2016.

Now, a contractor can protest “the issuance or proposed issuance of a civilian federal agency’s task or delivery order contract,” if the value of that order exceeds $10 million.

According to GAO statistics, for FY 2012 there were 2,475 protests filed with the GAO (U.S. General Accountability Office). In 2016 that rose to 2,789, so up a little bit more than 10% over four years. In 2012, protests were sustained, that is to say the protest was accepted, about 18% of the time. In 2016, that was up to 22.5%.

The three most common reasons to protest an order are:

  1. Brand name solicitation – The order references a brand name instead of the generic equivalent (e.g., Pepsi instead of cola).
  2. Out of scope modification – The agency adds work or changes a particular solicitation in a way that is out of the scope of that function. If the winning contractor got more work out of the original task order, the losing contractors were essentially shut out of bidding for those additional tasks.
  3. New information – The third most common reason to protest is new information that leads you to believe that the evaluation was unfair and that the losing contractor was “done wrong” by the government agency for not choosing them.

That third point is a big part of what protests normally come down to, i.e., “I don’t think you evaluated me (and/or the winner) fairly.” That may refer to evaluating price, technical proposal, or past performance.

Two other elements of protests are size standards, i.e., “I think these guys are too big for that NAICS code, even though they won the job,” and OCI (organizational conflict of interest), i.e., “I think the other company won because they were too close to the customer and learned secret information that helped them win.”

Without getting into the weeds, protesting when the evaluation is truly egregious is definitely a risk-reward kind of calculation, as the risks and legal costs can be quite high.


Five Connections To Grow Your Federal Business

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This is a guest post by Judy Bradt of Summit Insight.

Ever hear people complain that you’ve gotta have connections to win a contract? Well, they’re right! Here are the five kinds of connections you need to get on the fast track to growing federal business!

  1. Connect with passion.How excited are you about the difference you make for your federal buyers when they choose you instead of your competition? Bring the team together and refresh your key differentiators. Know how your past performance clearly shows your unique value to every federal buyer who is a true prospect. If you’re not special, you shouldn’t be there. If you are special, you need to know why, and articulate that in ways that each unique player cares about most. When you’re charged up about that, you’ll have the substance as well as the energy and determination to build the interest, enthusiasm and trust of your prospects on the road to “yes.”
  2. Connect with data. Past contract data is one of your best clues to the decision-makers you need to meet. Use my favorite super-powered tool, the Federal Procurement Data System, to dig in and figure out where your best prospects are. Then concentrate your efforts in those two or three agencies. Once you start making calls, one leads to another. The effort in each target agency, to develop each relationship, expands significantly once people start to open up to you. Expect to focus intense, methodical efforts on the right players, in the right layers, in your target agencies. Go deep.
  3. Connect with intelligence.Ever meet someone you were determined you wanted to date? And you wanted to make the perfect first impression? You asked their friends about what they enjoyed, how they like to spend their time, so you could start a conversation and propose a date with confidence! You might not have succeeded the first time, but you kept finding ways to woo your sweetie until he or she said “yes!” Think of wooing federal buyers the same way – the more you find out about them, the easier the conversations get. Beyond choosing your focus agencies, dip back into the data for what it tells you about your federal buyer, who they do business with, and how they buy. You can have that first conversation with a lot more confidence because you’re going in knowing things about them that they don’t expect.
  4. Re-connect with people you know. Invite your trusted friends, best clients and close contacts out for conversation and coffee. Let them know that you want to grow your federal business. You’ll find they’re eager to help you, with everything from references and resources to actual introductions! You just need to know what to ask them.
  5. Connect with new people.Want to win more federal business? That takes the courage, time, and money to go out and talk to a lot more people you’ve never met. Does the thought of going out and meeting new people and talking to them feel uncomfortable? Good news: you’re human. Just about everybody finds this challenging at least some of the time! The other four connections make that a lot easier.

Always remember: It’s the connection between that people opens the gate.


Employee Count NAICS Code Changes from SBA

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This is a guest post from Deltek’s GovWin IQ.

Deltek recently published an in-depth GovWin IQ analysis of the 2017 updates to NAICS code employee count size standards. SBA uses these standards to determine whether a business qualifies as a small business and is eligible for its set aside programs.

Here is a summary of those changes, reprinted with permission from the GovWin IQ report:

1. SBA increases small business size standards for NAICS Sector 31-33, Manufacturing

The SBA has issued a final rule to do the following:

  • Increase small business size standards for 209industries in NAICS Sector 31-33, Manufacturing.
  • Modify the size standard for NAICS 324110, Petroleum Refiners, by
    • increasing the refining capacity component of the size standard to 200,000 barrels per calendar day for businesses that are primarily engaged in petroleum refining; and by eliminating the requirement that 90percent of the output to be delivered be refined by the successful bidder from either crude oil or bona fide feed stocks.
  • Update footnote 5 to NAICS 326211 to reflect current Census Product Classification Codes 3262111 and 3262113.

SBA estimates that about 1,250 additional firms will become small because of revised size standards for the 209 industries in NAICS Sector 31-33.

2. SBA increases employee based size standards for industries in NAICS Sector 42, Wholesale Trade, and NAICS Sector 44 45, Retail Trade

The SBA has issued a final rule that:

  • Increases employee based size standards for 46 industries in North American Industry Classification System (NAICS) Sector 42, Wholesale Trade; Increases the employee-based size standard for one industry in NAICS Sector 44-45, Retail Trade; Retains the current size standards in the remaining industries in those sectors; Retains the current 500-employee size standard for Federal procurement of supplies under the non-manufacturer rule (13 CFR 121.406).

SBA reviewed all 71 industries in NAICS Sector 42 and two industries in NAICS Sector 44-45 that have employee-based size standards as part of its ongoing comprehensive size standards review as required by the Small Business Jobs Act of 2010.

Nearly 4,000 more firms in Sectors 42 and 44-45 will become small and therefore eligible for financial assistance under the revised employee based size standards. These revisions do not affect federal procurement programs. Newly eligible small businesses will generally benefit from a variety of Federal regulatory and other programs that use SBA’s size standards. Such benefits may include, but are not limited to, reduced fees, less paperwork, or exemption from compliance or other regulatory requirements.

3. SBA updates employee-based small business size standards for industries that are not part of Manufacturing (NAICS Sector 31-33), Wholesale Trade (NAICS Sector 42), or Retail Trade (NAICS Sector 44-45)

The SBA has issued a final rule to modify employee-based small business size standards for 36 industries and “exceptions” in SBA’s table of size standards that are not part of NAICS Sector 31-33 (Manufacturing), Sector 42 (Wholesale Trade), or Sectors 44-45 (Retail Trade). Specifically, the rule

  • Increases 30 size standards for industries and three “exceptions.”
  • Decreases size standards from 500 employees to 250 employees for three industries, namely NAICS 212113 (Anthracite Mining); NAICS 212222 (Silver Ore Mining), and NAICS 212291 (Uranium-Radium-Vanadium Ore Mining).
  • Maintains the Information Technology Value Added Resellers (ITVAR) “exception” under NAICS 541519 (Other Computer Related Services) as follows:
    • It retains the 150-employee size standard; and it amends footnote 18 to SBA’s table of size standards by adding the requirement that the supply component of small business set-aside ITVAR contracts (e., computer hardware and software) must comply with the nonmanufacturing performance requirements or nonmanufacturer rule.
    • Eliminates the Offshore Marine Air Transportation Services “exception” under NAICS 481211 (Nonscheduled Chartered Passenger Air Transportation), and NAICS 481212 (Nonscheduled Chartered Freight Air Transportation).
  • Eliminates the Offshore Marine Services “exception” for industries in NAICS Subsector 483 (Water Transportation), and their $30.5 million receipts-based size standards.
  • Removes footnote 15 (the “exception” to Subsector 483) from the table of size standards.

SBA estimates that about 375 additional firms may become small because of increased size standards for the 30 industries and three “exceptions” covered by this rule.

The revised size standards were effective as of February 26, 2016.

Source: SBA website; SBA’s final rule RIN3245-AG51 Regulations.gov (effective February 26, 2016)

This is essential information for small businesses looking to do contract work with the federal government. For more up-to-the-minute intelligence about the federal contracting landscape, check out Deltek’s GovWin IQ.


Restrictions for LPTA Procurements in NDAA FY17

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Contractors have complained for awhile about the government’s overuse of lowest-price, technically acceptable (LPTA) contracts. NDAA FY17 severely limits the use of LPTA evaluations in DoD procurements.

To use an LPTA methodology, the following criteria must now be met:

  • DoD is able to comprehensively and clearly describe the minimum requirements expressed in terms of performance objectives, measures, and standards that will be used to determine the acceptability of offers;
  • DoD would receive little or no additional value from a proposal that exceeded the minimum technical or performance requirements set forth in the solicitation;
  • Little or no specialized judgment would be required by the contract selection authority to discern the differences between competitive proposals;
  • The source selection authority is confident the bids from the non-lowest price offeror(s) would not produce benefits of additional significant value or benefit to the Government;
  • The Contracting Officer includes written justification for use of the LPTA scheme in the contract file; and
  • DoD determines that the lowest price reflects full life-cycle costs, including costs for maintenance and support.

The NDAA also cautions against the use of LPTA for these three types of contracts:

  1. Contracts that predominately seek knowledge-based professional services (like information technology services, cybersecurity services, systems engineering and technical assistance services, advanced electronic testing, and audit or audit readiness services);
  2. Contracts seeking personal protective equipment; and
  3. Contracts for knowledge-based training or logistics services in contingency operations or other operations outside the U.S. (including Iraq and Afghanistan).

As a final tool to gauge compliance, Congress mandated that the DoD publish annual reports for the next four years that explain the rationale for all LPTA contracts exceeding $10 million.


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