Comments on the Proposed Rule Regarding Credit for Lower Tier Small Business Subcontracting

PilieroMazza PLLC
Contact

Dear Ms. Fernandez:

We are writing to submit comments on the above-referenced Proposed Rule, issued October 6, 2015, 80 Fed. Reg. 60,300, to amend the U.S. Small Business Administration’s (“SBA”) regulations pertaining to small business subcontracting. Our firm represents a wide variety of firms operating across the government contracting spectrum. The intent of the Proposed Rule is to implement Section 1614 of the National Defense Authorization Act for Fiscal Year 2014. The relevant provisions of Section 1614 call for prime contractors with individual subcontracting plans to receive goaling credit for small business subcontractors performing at any tier, not just for the first tier subcontractors. While we believe many of the proposals are positive and will assist both large and small businesses working with subcontracting plans, we believe that there are several aspects of the Proposed Rule that could be amended to provide greater clarity and less burdensome outcomes for contractors administering subcontracting plans, particularly contractors that maintain commercial plans.

Please see full Comments below for more information.

LOADING PDF: If there are any problems, click here to download the file.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© PilieroMazza PLLC | Attorney Advertising

Written by:

PilieroMazza PLLC
Contact
more
less

PilieroMazza PLLC on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.