PilieroMazza recently submitted comments on the U.S. Small Business Administration’s Advance Notice of Proposed Rulemaking Regarding Women-Owned Small Business and Economically Disadvantaged Women-Owned Small Business—Certification issued December 18, 2015, 80 Fed. Reg. 78,984.
We represent many small business federal contractors, including women-owned and economically-disadvantaged women-owned small businesses (“WOSBs/EDWOSBs”). We submitted the comments to assist SBA in drafting a viable proposed rule that is fair and workable for WOSBs and EDWOSBs.
Click here to read our comments in their entirety:
- SBA Should Delay Implementation and Work to Change the Law
- SBA Certification Program
- If SBA Adopts the Certification Requirement, SBA Should Be the Only Certifier
- Streamlined Application Process
- Concurrent Certification Through 8(a) Program
- Term of SBA Certification
- Third Party Certification
- New Regulations & Procedures Are Needed if SBA Permits Third Party Certification in Addition to SBA Certification
- All Certifiers Should Apply or Re-Apply
- Term of Third Party Certification
- No Repository Access for Third Party Certifiers
- Mentor-Protégé Agreements and Joint Venture Agreements
- SBA Should Clarify Applicability of the Certification Requirement to WOSB and EDWOSB Industries
- Certification by States and Other Federal Agencies
- State WOSB/EDWOSB Certification Authority
- Acceptance of DBE Certifications in Determining Ownership and Control
- State Entities’ Expertise
- Other Federal Agency Certification, Including Contract-Specific Certification
- WOSB/EDWOSB Protests of Firms Not Certified by SBA
Please do not hesitate to contact Pamela Mazza, Jon Williams, Katie Flood or Megan Connor at 202.857.1000 if you have any questions about these comments.