HUBZone CertifiedHow to Direct Awards to C22
Benefits of a HUBZone Sole Source Award
Your agency has a goal to award a minimum percentage of contracts (minimum 3%) to Historically Underutilized Business Zone (HUBZone) small businesses concerns (SBCs). You can help your agency achieve this goal through a process that is both easier and faster than traditional acquisitions while supporting job creation for economically disadvantaged communities. It is especially easy to make your acquisition using the HUBZone sole sourcing process. This document provides information about how straightforward and beneficial the process is.
Types of HUBZone Contracts
Per 13 CFR § 126.600, there are several principal ways to contract with a HUBZone company, and the Contracting Officer (CO) is responsible for identifying which method to use:
- A Competitive Set-aside contract can be awarded by the CO, including partial set-asides, if the CO has a reasonable expectation that at least two responsible qualified HUBZone SBCs will submit offers and that the award can be made at fair market price.
- A Sole source contract can be awarded by the CO if they do not have a reasonable expectation that at least two responsible qualified HUBZone SBCs will submit offers and determines that the award can be made at fair market price. The estimated award value cannot exceed $7,500,000 for a contract assigned a manufacturing NAICS code, or $4,500,000 for all other contracts (FAR 19.1306).
- Awards to certified HUBZone SBC through full and open competition after a price evaluation preference is applied to an other than small business in favor of certified HUBZone SBC;
- Awards based on a reserve for certified HUBZone SBCs in a solicitation for a Multiple Award Contract (MAC) (13 CFR § 125.1); or
- Orders set-aside for certified HUBZone SBCs under a MAC that was awarded in full and open competition.
Benefits of Sole Sourcing a HUBZone Contract
COs and Program Managers (PMs) save a substantial time, effort, and cost during the procurement cycle through a HUBZone sole source award. HUBZone contracts can be acquired non-competitively when the value of the contract does not exceed $4.5 million (applicable to services). These benefits include:
- There is no required System for Award Management (SAM) synopsis for sole source HUBZone contracts.
- Every federal agency has percentage goals for HUBZone contracts to meet each year. Sole sourcing a HUBZone contract simultaneously will help meet your agency’s HUBZone and small business goals.
- After your first HUBZone sole source award, you will recognize how easy and efficient it is, and you will have established a repeatable process for sole sourcing to HUBZone SBCs new opportunities, saving time and effort while shortening the procurement cycle and helping your agency to achieve its HUBZone goals.
Sole Source Versus Small Business Set-aside or Full and Open Competition
It is possible to issue a small business set-aside or a full and open solicitation then, if a HUBZone SBC is the successful offeror take the HUBZone credit. However, both the Small Business Administration’s (SBA’s) regulations and the FAR require that, for acquisitions exceeding the Simplified Acquisition Threshold, the CO must first consider a set-aside or sole source award (if the sole source award is permitted by statute or regulation) under the 8(a) BD, HUBZone, SDVO SBC or WOSB programs before setting aside the requirement as a small business set-aside (see 13 C.F.R. §§ 124.503(j), 125.2(f), 125.19(b), 126.607(b), 127.503(d); FAR 19.502-2(b); FAR 19.1306. There is no order of precedence among the 8(a) BD, HUBZone, SDVO SBC or WOSB programs. To do so, the CO must:
- Document the contract file with the rationale used to support the specific set-aside, including the type and extent of market research conducted.
- Document the contract file showing that the apparent successful offeror’s certifications in SAM (or successor system) and associated representations were reviewed.
SBA believes that progress in fulfilling the various small business goals, as well as other factors such as the results of market research, programmatic needs specific to the procuring agency, anticipated award price, and the acquisition history, should be considered in deciding which program to use for the acquisition. Although agencies can take HUBZone small business credit if a HUBZone SBC is awarded a contract using a general small business set-aside or full and open competition, this strategy significantly reduces an agency’s chance to meet the statutory 3% HUBZone goal.
How to Award a Sole Source Contract
While each agency’s internal process and procedures may vary, the fundamental sole source award process is:
- The PM or CO identifies the procurement need as a set-aside for HUBZone SBCs and determines the total award value to be less than $4.5 million for service or $7.5 million for manufacturing contracts.
- They identify a HUBZone firm capable of performing the work.
- The PM or CO coordinate on the DD Form 2579 (Small Business Coordination Record) and issue an offering letter to the SBA district office that handles the selected HUBZone firm.
- The SBA office reviews the offering letter and accepts (or declines, if the firm is deemed unable to perform the requirements) within five business days. (FAR 19.1305 (d)(1))
- Upon acceptance by the SBA office, the CO can issue the solicitation to the HUBZone SBC. (FAR 19.1306)
About Sole Sourcing to Century 22 Solutions
Century 22 Solutions (C22) is a certified HUBZone Small Business Concern providing innovative solutions and inventions (“innoventive”) to federal, state, and local governments as well as to commercial businesses. A technology services and solutions company, C22 provides integration, UAV, R&D, and soft diplomacy services to government and commercial clients to solve today’s most pressing challenges. Being in the heart of Gainesville, Florida’s Innovation District and as a resident client of the University of Florida Innovate | The Hub business incubator, C22 is well positioned to bring leading edge and emerging technologies to the marketplace as applied solutions. C22’s principle NAICS codes include:
541510 – Computer Systems Design and Related Services
541511 – Custom Computer Programming Services
541512 – Computer Systems Design Services
541519 – Other Computer Related Services
541600 – Management, Scientific, and Technical Consulting Services
541610 – Management Consulting Services
541611 – Administrative Management and General Management Consulting Services
541612 – Human Resources Consulting Services
541613 – Marketing Consulting Services
541618 – Other Management Consulting Services
541690 – Other Scientific and Technical Consulting Services
541713 – R&D Nanotechnology
541714 – R&D in Biotechnology (except nanotechnology)
541715 – R&D Physical Engineering and Life Sciences (except bio and nanotechnology)
541720 – R&D in the Social Sciences and Humanities
541890 – Other Services Related to Advertising
541990 – All Other Professional, Scientific, and Technical Services
541618 – Other Management Consulting Services
336411 – Aircraft Manufacturing
C22 is a certified SBA HUBZone Small Business Concern. Please contact us for more information.
HUBZone Small Business Concern Certification Information
Certificate Number: 65713
Certification Date: 04/01/2021
Recertification Date: 03/31/2022
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