The Biden Administration’s focus on enhancing opportunities for small businesses provides a timely occasion for federal managers to take stock of current acquisition strategies, processes, and requirements that impact business opportunities in the federal marketplace. This blog focuses on the government’s long-running success in promoting small business opportunities in federal acquisition. Over the years, GSA, to its credit, developed an acquisition strategy centered on a portfolio of standalone small business GWACs that exist in addition to its other governmentwide contract vehicles that are dedicated to meeting customer agency mission support through the use of small business contracting. It is not an overstatement to say that the success of this strategy in supporting small businesses is unparalleled in federal acquisition.

As you know, in the last decade, GSA’s IT GWAC portfolio included Alliant Unrestricted as the GSA GWAC open to other than small businesses. (Alliant 2 is the current follow-on to the original Alliant Unrestricted.)  GSA built its portfolio of small business GWACs around Alliant Unrestricted, providing streamlined access to small businesses across the socio-economic categories. GSA’s small business GWACs, Alliant Small Business (SB), 8(a) STARS II and the follow-on STARS III, VETS, and VETS 2, have given rise to more than $22.2 billion in task orders with small businesses, accounting for 43.8 percent of total GSA GWAC spend over the last nine years. This spending result is well-above the federal government’s 23 percent small business contracting goal.

There has been a decline in small business spending due to the expiration of Alliant SB.  The good news here, however, is that GSA has embarked on Polaris, the new follow-on procurement that will replace Alliant SB.  Still, in 2020, the GSA GWACs saw 40.1 percent of spend going to small businesses, again, well-above the aforementioned government small business contracting goal.  The upcoming award of Polaris should fill this void.

As with many things in life, in the world of IT GWACs and governmentwide contracting vehicles, imitation is the sincerest form of flattery. The IT GWAC program managed by NIH has included an IT GWAC, NIH CIO SP3, set-aside exclusively for small business concerns. The resulting performance in providing opportunities for small business has been outstanding. Since 2012, there has been more than $7.6 billion spent with small businesses through CIO SP3, accounting for 44.9 percent of total CIO SP3 spending.

Similarly, in 2014, GSA established its governmentwide professional services IDIQ, OASIS and OASIS SB.  Since 2014 and the awards of OASIS and OASIS SB, there has been more than $12.8 billion for small businesses through OASIS SB accounting for 43.9 percent of total OASIS program spending.

Streamlining is at the heart of the remarkable success of the standalone small business IT GWACs and OASIS SB. The standalone approach removes process-related hurdles associated with set-aside contracts and/or orders. It provides a streamlined, direct model where task orders are issued within a platform (contract vehicle) made up exclusively of small business concerns. In essence, GSA and NIH have done the upfront work for customer agencies in creating the small business eco-system for competition in meeting mission requirements. Moreover, the creation and maintenance of the standalone small business IT GWACs and OASIS SB sends a powerful message about the federal government’s strong commitment to procurement opportunities for small businesses.

Significantly, despite its successful track record in supporting small businesses, NIH has chosen to abandon the standalone small business IT GWAC model in its follow-on CIO SP4 procurement. The current structure brings small, medium, and large businesses together on a single contract vehicle. This approach increases complexity at the order level when customer agencies seek to set-aside work. Even more importantly, it lowers the profile of the small business portion of the NIH CIO SP4. No longer will the small business community and the customer agencies have a high-profile, streamlined, and separate contract vehicle dedicated to small business IT procurement opportunities.

Just as significantly, GSA is considering eliminating OASIS SB as part of its acquisition strategy for the OASIS program follow-on, the “Services MAC.”

Given the outstanding track record of GSA’s small business IT GWACs, NIH’s CIO SP3 small business GWAC, and OASIS SB, the abandonment of the acquisition approach of these vehicles in their follow-on procurements appears to be inconsistent with increasing opportunities for small businesses. Notwithstanding the fact that these acquisition strategies originated over the last 24 months, it is hard to square these approaches with the Biden Administration’s increased commitment to small business opportunities in federal procurement.