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Acquisition Policy Flash! 12-15

Reminder!

Department of Veterans Affairs Veteran Owned Small Business Verification and Small Business Administration Small Business Size Standards

Purpose:  To remind the VA Acquisition Workforce that the Small Business Administration (SBA) determines small business size standards not the VA Office of Small and Disadvantaged Business Utilization, Center for Veterans Enterprise (CVE).

Dated:  September 27, 2012

Background:  The VA Office of Procurement Policy and Warrant Management Service has been informed that some Service-Disabled Veteran-Owned Small Business (SDVOSB) or Veteran-Owned Small Business (VOSB) procurement actions may have been inaccurately recorded as small business awards based on the CVE verification of Veteran ownership and control.

The official source for a firm’s representations as to its small business size is the firm’s response to FAR clause 52.219-1.  A firm’s submission to the On-line Representations and Certifications Application (ORCA) is the source for this information.  Neither the CVE Vendor Information Pages database nor the Central Contractor Registration is a substitute for the formally attested submission in ORCA.

Guidance:

  1. The CVE verification of SDVOSB or VOSB status does not supersede the SBA small business size standards.

  2. Contracting Officers (COs) shall review a firm’s representations and certifications in ORCA to determine, based on the acquisition-specific NAICS code, if the business is small.

  3. Because small business status is a requirement for the Veterans First Contracting Program, COs shall not award to an SDVOSB or VOSB under this program where the business has not represented itself as small for the applicable NAICS code in ORCA.

Note:  As of July 29, 2012, ORCA, Central Contract Registration (CCR), Federal Agency Registration (FedReg), and the Excluded Parties List System (EPLS) will be accomplished via the System for Award Management at:  www.sam.gov.

For questions or concerns regarding this Acquisition Policy Flash, please contact Eyvonne Mallett, Senior Procurement Analyst, at va.procurement.policy@va.gov.