An SBA pilot program is in the works to ultimately improve the competitive market for prime contract bids by having past performance history documented and available as a tool for ratings. The 2017 National Defense Authorization Act provides certain small subcontractors a way to request past performance ratings from the government. Consequently, for this reason, small contractors trying to obtain contracts in the federal marketplace have a difficult time competing without access to past performance numbers.
It is difficult to prevail in a “best value” competition without some kind of past performance rating from the government. Incidentally, FAR 15.305 says the government can consider past projects for non-government entities, however, it also states that if the offeror doesn’t have a relevant past performance they receive a “neutral” rating. Most contractors agree, if an offeror doesn’t have a performance rating from the past, it presents a significant competitive disadvantage.
The SBA pilot program is designed for subcontractors working on government contracts to develop a subcontracting plan and submit an application to the appropriate official. Subcontractors may offer a suggested rating with written documentation to back it up. At this point, the Office of Small Disadvantaged Business Utilization and a prime contractor review the submissions and submit an official response within 30 days.
The statute says the Small Business Administration will establish the pilot program but there is no specifics on a deadline. The program, once up and running, is scheduled to last for three years. It appears that Congress anticipated improvements for the pilot program. The GAO is required to assess the program one year after it is established and prepare a report of findings to present to Congress.
If you have questions about the SBA pilot program or past performance ratings, contact KDuncan and Company, we’re here to help!
KDuncan & Company is dedicated to providing knowledge and support for small government contractors about concerns regarding government contracting. For questions on areas such as as cost proposals, accounting systems, DCAA compliance, and incurred cost audits, reach out to KDuncan & Company.