24 Organizations Ask SBA to Expedite Sole Source for Women
Monday, January 26, 2015
24 Organizations Ask SBA to Expedite Sole Source for Women
WIPP, along with 23 organizations representing the women’s business and small business communities, submitted the below letter to the SBA asking them to expedite sole source authority. With sole source regulations already in place for other small business contracting programs, the addition to the WOSB Procurement Program can and should be done immediately. The additional WOSB certification changes, also contained in the new law, should follow the full regulatory process.
January 20, 2015
The Honorable Maria Contreras-Sweet
U.S. Small Business Administration
409 Third Street SW
Washington, D.C., 20416
Re: Promulgation of Section 825 (WOSB Sole Source) of FY15 National Defense Authorization Act (NDAA)
Dear Administrator Contreras-Sweet,
On behalf of the women’s business community, we urge you to expedite regulations allowing for sole source authority in the Women-Owned Small Business (WOSB) Federal Contract Program (“Procurement Program”). While other provisions affecting the WOSB Procurement Program will require regulatory attention, their promulgation will likely be lengthier. Given the immediate need for sole source authority and the probable duration of certification reforms, we ask that the provisions of Sec. 825 of the FY15 NDAA (P.L. 113-291) allowing for sole source authority be implemented in the timeliest manner and separately from the implementation of certification changes.
We believe this action will immediately assist the federal government in meeting its goal of awarding 5% of all prime contract dollars to women-owned small businesses.
The Immediate Need for Sole Source Authority
The women’s business community is a diverse and thriving group of entrepreneurs totaling nearly eight million women, whose businesses contribute more than $1 trillion annually to the economy. Minority women business owners, including nearly two million Black and Hispanic women, make up one third of this community—a number that has doubled in the last two decades. The women’s business community is a critical segment of the business community and the American economy.
Nevertheless, women entrepreneurs remain underrepresented in the federal marketplace. Currently, women-owned small businesses, despite offering innovative and unique services and products, must find other women-owned small businesses to respond to federal government solicitations before the WOSB Procurement Program can be utilized.
Section 825 of the FY15 NDAA removed that barrier by allowing contracting officers to award sole-source contracts up to $6.5 million for manufacturing contracts and $4 million for all other contracts, consistent with other small business contracting programs. After waiting more than a decade to see the WOSB Procurement Program function effectively, the women’s business community hopes for an expedited implementation of this change.
There is precedent for moving swiftly to improve the program. In 2013, a statutory change to remove the dollar caps on contracts awarded through the program was put into effect six months after enactment. Doing so tripled the amount of dollars awarded through the WOSB Procurement Program.
By promulgating an interim final rule and urging FAR Council adoption, SBA made a real difference to women entrepreneurs. Doing so again will be a clear statement that achieving the 5% goal as soon as possible is a top priority of the Administration.
Implementing New Requirement for Certification
In the FY15 NDAA Congress also required SBA to amend the certification process for the WOSB Procurement Program. The law removes the current option of self-certification and gives the SBA the option of creating a new certification process for the WOSB Procurement Program.
This change will fundamentally alter the environment for women entrepreneurs in the federal marketplace. Ensuring that the regulations implementing this change are done thoughtfully, with the input of stakeholders, and through the formal regulatory process is of maximum importance. In our view, the regulatory process for certification will take significantly more time than allowing sole source authority. Waiting to implement both will unduly delay improving the WOSB Procurement Program.
When women entrepreneurs compete, it fosters significant business growth. The Small Business Act describes this growth well, noting that the country’s “well-being cannot be realized unless the actual and potential capacity of small business is encouraged and developed.” Encouraging and developing women-owned businesses in federal procurement is at the heart of this program. Ensuring participation through sole-source contract awards will allow these businesses to compete for government contracts and greatly enhance the WOSB Procurement Program.
We, the undersigned, urge you as the SBA Administrator, to implement sole source authority as soon as possible. Doing so will strengthen a fourteen year effort to create a successful program supporting America’s women entrepreneurs.
Arizona Small Business Association
Association for Enterprise Opportunity
Association of Women’s Business Centers
Baltimore Washington Corridor Chamber
California Association for Micro Enterprise Opportunity
Colorado Women’s Chamber of Commerce
Montgomery County Chamber of Commerce
National Association for Female Executives
National Association of Certified Government Business Enterprises
National Association of Women Business Owners
National Association of Women Business Owners – Greater DC Chapter
National Association of Women in Real Estate Business
National Defense Industrial Association
National Women Business Owners Corporation
Small Business & Entrepreneurship Council
Small Business Association for International Companies
The Insurance Exchange
U.S. Black Chambers, Inc.
U.S. Hispanic Chamber of Commerce
Women Impacting Public Policy
Women In Defense
Women Presidents’ Organization
Women’s Business Development Council