Comments on Notice–MV–2017–01, Evaluation of Existing Acquisition Regulations

Publications, Comments 08.15.17

The U.S. General Service Administration’s (“GSA”) is seeking input on acquisition regulations, policies, standards, business practices and guidance issued by GSA across all of its acquisition, disposal, and sales programs, that may be appropriate for repeal, replacement, or modification. We represent many small businesses that participate in the various procurement programs administered by GSA, in particular contract vehicles under GSA’s Federal Supply Schedule program. Although there are many issues that touch upon small business concerns that hold these contracting vehicles . . . Read More

Office of Management and Budget ( OMB ) Circular A-xxx

Publications, Comments 11.07.16

Includes our comments on : Aspects of the Circular Require Clarification We recognize that OFPP sees a value in Category Management and intends to institutionalize Category Management principles across the Government. However, clarification of the Government’s approach, as set forth in the proposed Circular, is needed. Consideration of Small Businesses Should Be Required More consideration of small businesses is needed. BIC Sourcing Solutions Must Be Readily Attainable The Circular does not address how competitions for BIC preferred and BIC mandatory . . . Read More

Our Comments in Response to FAR Case 2015-15 Regarding the Federal Strategic Sourcing Initiative – FSSI

Publications, Comments 08.19.16

PilieroMazza recently submitted comments to the General Services Administration stating that the proposed rule should not be applied in small business set-asides, the brief analysis should allow for flexibility, and the notice of proposed rulemaking understates the impact on small businesses.  Click here to read the proposed rule Click here to read our comments submitted to SBA 

Our Comments in Response to the GAO’s Proposed Rule Regarding Electronic Filing System and Filing Fee

Publications, Comments 05.17.16

Read our full comments here Excerpts Filing Fee The new rule envisions imposing a filing fee of $350 on protesters. We respectfully request that an exception to the fee be created for small businesses, as defined under the Small Business Act, in order to mitigate against the burden of this requirement. Redactions  While we concur with the creation of a rule providing for a redaction process, we respectfully request that the rule allow the parties to opt out of creating redacted versions of protest documents . . . Read More

Comments on Proposed Rulemaking Regarding WOSB and EDWOSB Certification

Publications, Comments 02.16.16

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 . . . Read More

Comments on Advance Notice of Proposed Rulemaking Regarding Women-Owned Small Business and Economically Disadvantaged Women-Owned Small Business Certification

Publications, Comments 02.16.16

Includes comments on: 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 . . . Read More