The difficulties faced by new small businesses lacking past performance ratings in winning federal contracts are well-known. Perhaps the most common approach by which new small businesses get their start in federal contracting is by working as a subcontractor to a federal prime contractor. Often this is accomplished by working as a subcontractor under federal prime contracts that require the prime contractor to develop a subcontracting plan. For small businesses that perform as first-tier subcontractors under such federal contracts and lack past performance ratings as a prime contractor, Congress has provided for a new “pilot program,” under section 1822 of the recently-enacted 2017 NDAA. Under the pilot program, these first-tier subcontractors can obtain a past performance rating in the federal past performance system that they can use to obtain a federal prime contract.
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