Washington Management Group

Small Businesses Just Got Larger

Practical Advice on GSA Schedule Contracting
By: Carolyn Alston, General Counsel, Washington Management Group

March 2012

Small businesses will welcome the news that the Small Business Administration has increased 37 size standards in industries that fall under the umbrella of Professional Technical and Scientific Services. Some of GSA's most popular schedules, including the ones in the chart below, contain NAICS codes for these industries.

Schedule FY 2011 Sales
70 GENERAL PURPOSE COMMERCIAL INFORMATION TECHNOLOGY EQUIPMENT, SOFTWARE, AND SERVICES $15,723,563,644
541 ADVERTISING & INTEGRATED MARKETING SOLUTIONS (AIMS) $426,328,462
738 X HUMAN RESOURCES & EQUAL EMPLOYMENT OPPORTUNITY SERVICES $239,770,848
871 PROFESSIONAL ENGINEERING SERVICES $2,869,069,272
874 MISSION ORIENTED BUSINESS INTEGRATED SERVICES (MOBIS) $5,107,855,428

Click here to see a list of all NAICS codes with changed size standards

The increases in size standards are significant, in some circumstances doubling from $7 million to $14 million dollars. GSA Schedules in addition to those listed above may be impacted because one of the size standards increased is for NAICS 541990 "All Other Professional, Scientific and Technical Services". This NAICS code is included in a number of professional services contracts.

Also good news for small businesses, a FAR interim rule recently clarified that Federal agency contracting officers have authority to set aside business at the task order level for small business concerns. GSA is in the process of refreshing standing solicitations and modifying existing contracts to insert required FAR clauses. The new size standards, coupled with clear authority of contracting officers to set aside requirements could increase small business opportunities under the GSA Schedule program. The GSA Schedule is already 'small business friendly' with historically more than 30% of sales going to concerns in this category.

The new size standards are effective this week, March 12, 2012. I hope that GSA will allow contractors affected by the revised standards to update their size status immediately. I have, however, received varying answers as to whether that will happen. There has been some discussion that the agency would tie implementation of the size standards to implementation of the new 2012 NAICS codes. The new NAICS codes will not be implemented until October of this year. WMG will continue to follow GSA efforts to implement the new size standards. We will update you if we find out more.

Do you have a government contracting question? Please email it to me at CarolynsCorner@washmg.com.

About Carolyn:

Carolyn Alston is General Counsel of Washington Management Group. She provides legal counsel to WMG's federal acquisition consulting operation, focusing on Multiple Award Schedule contract award, compliance, and audit procedures.

Prior to joining WMG, Carolyn had a distinguished career with the U.S. General Services Administration. Her experience as a senior attorney in the GSA's Office of General Counsel led to her role as the lead in developing and writing GSA's Multiple Award Schedule policy. Her GSA career culminated in running the agency's successful GSA Schedule program as Assistant Commissioner for Acquisition at GSA.

Carolyn holds a BA from Cornell University and a JD from Georgetown Law Center. Carolyn is a member of the bar in Maryland and the District of Columbia.



DISCLAIMER

WMG offers the information provided on this web site for informational purposes only.

WMG is a well recognized expert in GSA Schedule contracting, with more than 30 years of corporate experience. The information provided on this site is based on our substantial acquisition expertise, particularly with respect to commercial item contracting. Nothing on this site should be interpreted as legal advice.

As you recognize, most decisions regarding your GSA Schedule contract are highly dependent upon the facts of your particular circumstances. You should not rely on this site to make specific decisions about your contract. If you are considering taking specific actions on a matter affecting your GSA Schedule contract, we highly recommend that you contact WMG regarding a proposal for individual acquisition consulting services or that you seek advice from legal counsel with expertise in GSA Schedule contracting.

   

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