Let’s Fix This by Ann Sullivan, WIPP Government Relations
Monday, June 1, 2015
Let’s Fix This
By Ann Sullivan, WIPP Government Relations
As most of you know, WIPP has been at the forefront of fighting for a successful women’s procurement program for more than a decade. Eleven years after the law was passed, the Small Business Administration (SBA) finally put the program into place. With every objection, we overcame it by securing a lifting of the dollar caps on awards and getting sole source authority in the program (pending SBA final rulemaking).
Enter a report by the SBA Office of Inspector General (OIG), which took a look under the hood of the WOSB procurement program. And they didn’t like what they saw. The report found that contracts awarded through the program had been done so mistakenly. A major issue was failure of women-owned businesses to fully register in not just the System for Award Management (SAM), but also in the SBA Repository. To be eligible, a WOSB must register in both. Many overlooked the repository (more on that below).
Citing misuse and confusion by contracting officers, the report raised concerns about management of the WOSB procurement program. Critical oversights included improperly setting aside contracts in industries not served by the WOSB program as well as failures by women business owners to upload all the necessary documents to the WOSB repository.
Efforts to educate contracting officers already include adding WOSB to the contracting education curriculum at agencies as well as SBA’s ChallengeHER program (done in partnership with WIPP), which educates both procurement professionals and entrepreneurs. Women business owners too can be part of the solution.
WIPP encourages all women business owners to ensure they are updated in the SAM; make sure all necessary documents have been uploaded to the WOSB repository (find the full list under repository links on SBA’s WOSB page); and ensure a contract is being set-aside in the right NAICS codes (find the WOSB and EDWOSB NAICS codes here). A webinar with SBA on certification is available on WIPP’s website.
The WOSB procurement program was created to help women entrepreneurs. With it came the rules of how the program can be used. It is up to us, as possible beneficiaries, to be just as responsible as a contracting officer. It will come as no surprise to those familiar with federal contracting that those officers have a difficult job. Ensuring that we have all done our part, to be properly certified and registered in the repository, is simply good business to keep contracting officers interested in the program.
The report’s author, SBA’s Office of Inspector General, is also the lead on fighting fraud in the program. WIPP has long advocated in support of this program and increasing access to federal markets for genuine women business owners. If you suspect fraud in the program, report it to SBA. It is the OIG’s responsibility to follow up on all reports of fraud. We should at least know the timetable and number of reports for these investigations. Given the relative newness of the program, everyone will benefit from understanding the program and the access to federal contracting it provides to women owned companies.
I would also add, as someone who has very personally fought for the success of this program, that those companies wrongfully taking advantage of this program are hurting everyone. While we all feel pressures to gain an edge in competition and in business, fraudulently using this program only stands to threaten all women entrepreneurs. It embarrasses me as a women business owner myself that women would so recklessly throw aside this enormous opportunity.
Keeping this program beyond reproach is critical to both the program’s future and WIPP’s advocacy. The first step is informed women entrepreneurs. I challenge everyone to make sure you have submitted all the required documentation to the WOSB repository, know the rules of the program, and if you see fraud, report it.