I am told that DOJ will be issuing guidance to agencies shortly about how to handle current and prospective/approved 8a contractors and 8a awards and comply with the Court’s decision. This is an evolving issue so keep watching this space.
The following are my suggestions based on the information I’ve received:
- EVERYONE is required to write a narrative statement that tends to prove their social disadvantage and everyone must do so by submitting a narrative statement that tends to prove their social disadvantage.
- SBA will make all final decisions (approve/decline) on narratives prior to certifying your company for 8a participation; or prior to allowing an Agency to make an award to your company.
- So that we’re clear: If you are currently in the process of applying for 8a status (and you don’t have an acceptance yet) OR you are an approved and active 8a company that is trying to secure a contract award,- in either case – YOU MUST create a narrative statement that tends to prove your personal experiences of social disadvantage and how those experiences have adversely affected you and denied you opportunities in education, finance, business etc. I suggest that you use the guidelines outlined in section 13 CFR 124.103(c) which can serve as a structured framework for your narrative.
- It is crucial to understand that there are no exceptions or special cases. Every individual must adhere to this requirement without deviation.
- Time is of the essence since we’re near the end of fiscal year.
- The 8a program is still active – it is not discontinued.
- Some Agencies are trying to avoid making 8a awards entirely and SBA is negotiating with them.
I’m trying to help the industry stay ahead of the curve by providing up to date, and reliable information to help you to prepare – forewarned is forearmed. I will update again shortly – to give you tips on how to write a successful narrative.
Source: Robb Wong, Former SBA Associate Administrator, Office of Government Contracting & Business Development
and a follow-up post here focused on “HOW TO WRITE A SUCCESSFUL SOCIAL DISADVANTAGE NARRATIVE”
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