Time Sensitive: Submit your comments on the Proposed Rule for the implementation of the Women-Owned Small Business Federal Contracting Program
Comments are to be submitted no later than May 3, 2010.
Dear friends and supporters -
After more than a decade of waiting, the SBA has finally published a set of Proposed Rules to implement the Women-Owned Small Business Federal Contracting Program that, with some refinement, will serve to implement a strong program enabling restricted competition for certain women-owned small business on contracts within selected NAICS codes. This program should help the federal government to meet their mandate for providing a fair portion of Federal contracts to women-owned small businesses.
>>Learn more about the program. >>Read the proposed rule. >>View the list of industries included. >>Register to receive updates
I ask you to please stop right now, prepare and submit your comments for the implementation of the Women-Owned Small Business Federal Contracting Program using the information and links provided below.
Margot Dorfman, CEO
U.S. Women's Chamber of Commerce
Use the information below to submit your comments
It is vitally important that your voice be heard in this process. Your strong and ongoing support for the Women-Owned Small Business Federal Contracting Program has kept the voice of women-owned small businesses alive before the SBA, Congress, the media, and our community.
IMPORTANT: When you are ready to submit your comments go here to the government regulations website, click on "Comment Due" (lower left), complete the form and copy/paste in your comments (or upload a file) into the area provided. Be sure to click on "Submit" when you are done. The correct Document ID is SBA-2010-0001-0001. If you have any challenges, please contact us and we will help you through the process to submit your comments.
Keys to your comments:
Open an empty word pad, text or word document and prepare your comments. When you are ready, follow the instructions above to submit your comments.
Please include that you join with the comments provided by the U.S. Women's Chamber of Commerce in support of the expedient implementation of the Women-Owned Small Business Federal Contracting Program to help bring to an end the failure of the Federal government to provide a fair portion of Federal contracts to women-owned small businesses.
(1) Start your comments with a brief statement about your firm (where you are located, your industry, when you were founded, your size included employees and revenues, and how much it means to you, your employees, your family and community that a fair portion of federal contracts are awarded to women-owned small businesses). Include any hardships or discrimination you have faced.
(2) State a general support for the Proposed Rules with a few key exceptions/recommendations for alteration or inclusion of additional details.
(3) Include these items within your recommendations.
(a) The SBA should follow the recommendations of the National Resource Council (NRC) of the National Academy of Sciences and use both Central Contractor Registration (CCR) data and the Survey of Business Owners (SBO) when determining the "ready, willing and able" status of women-owned small business thereby opening the Women-Owned Small Business Federal Contracting Program up to more industries in which women are underrepresented.
[Background: The method used by the SBA for the selection of underrepresented and substantially underrepresented industries should include a broader look at businesses that are, "ready, willing, and able" to perform government contracts. Using only the CCR database (the Central Contractor Registration) is too limiting and may build the selection of industries upon a database that already reflects years of discrimination and frustration. The National Resource Council recommended to the SBA that two sets of data be used when looking at women-owned small businesses that are "ready, willing and able" to perform federal contracts -- CCR and the Survey of Business Owners (SBO) provided by the U.S. Census.]
(b) The SBA should set a clear methodology and timeline for determining updates to the list of industries included in the program.
(c) Given the wide variance of incomes and cost of living across the U.S. and the potential for inflation, we recommend the SBA, (1) establish location specific guidelines based on median regional incomes much like the IRS publication 1542 which details per diem rates based on local expense averages, (2) peg the location specific guidelines to an automatic inflation adjustment so that the level set to determine an EDWOSB firm will automatically adjust overtime without the need for additional regulations or intervention by Congress.
[Background: The SBA proposed rule states, "When considering a woman’s personal income, if the adjusted gross yearly income averaged over the two years preceding the certification exceeds $200,000, SBA will presume that she is not economically disadvantaged."]
(d) The SBA should immediately accept both DOT DBE and all State government (including regional government) certifications rather than requiring the DOT and dozens of state governments to go through a third-party certifier agreement process with the SBA. The legislation, as set forth by Congress, does not require Federal or State government agencies to put agreements into place with the SBA. This type of bottleneck in the process will only serve to limit the use of the program by women-owned small businesses and further the descriminatory practices that have lead to the underrepresentation of women-owned small businesses in the federal contracting arena.
(e) The SBA should accept all third-party certifiers (non-governmental) that meet the stated standards for certification as detailed in the Final Rule. This will serve to assure a wide range of options for women-owned small businesses within the certification process.
(f) The SBA should either secure from the DOT a complete list of DBE certifications that include the authentication of women-owned status and accept the certifications from women-owned firms from this database, or request the DOT to expediently provide women-owned DOT DBE certified firms with a clear document affirming their women-owned status. The current language in the Proposed Rule will create confusion and potentially prevent many women-owned firms certified by the DOT from effectively leveraging this certification for use in the Women-Owned Small Business Federal Contracting Program.
(g) The SBA should clearly state within the Final Rule that only firms who have successfully completed the certification and/or self-certification process as detailed in the Final Rule shall be eligible for achievement of SBA women-owned small business goaling reports. One standard must be in place for all reporting of women-owned small business federal contracting goal achievement.
(h) The SBA should include in the final report a method for businesses from industries not included in the SBA recognized list of industries underrepresented in federal contracting to appeal for placement of their industry in the list.
IMPORTANT: When you are ready to submit your comments go here to the government regulations website, click on "Comment Due" (lower left), complete the form and copy/paste in your comments (or upload a file) into the area provided. Be sure to click on "Submit" when you are done. The correct Document ID is SBA-2010-0001-0001. If you have any challenges, please contact us and we will help you through the process to submit your comments.