What does this have to do with Federal Proposal support you may ask? Both are indeed morality tales that make us all wonder if it is now okay to inflate our resume or to certify a NAICS code to win a Federal Contract in today’s highly competitive landscape.
Recently one of the high-flying minority contractors in Northern Virginia made the front page of the Washington Post because of their alleged false statements to both the VA and the SBA to gain over a billion dollars of contracts at the VA under a specific NAICS code set aside for small businesses. The final results of the investigation by the VA, SBA and now Congress have yet to unfold. But you can be sure that future business owners would rather be highlighted for community service than for falsification of their contract representations.
All large contractors live in fear of being the front page article in a national newspaper or the target of a famous internet blog.
Small contractors should heed that fear as well when their future success or failure hangs in the balance when they certify their compliance to a Federal Procurement requirement upon submission.
Compliance to the requirements of Federal Procurements today is more difficult than many believe and is a bitter pill for companies that have spent tens of thousand of dollars internally and externally to produce a proposal only to find out they are not in compliance once submitted.
Even if you do your proposals in house, you should have someone external with understanding and knowledge of the procurement do a final compliance review and check of all submissions. Understanding that a “Mandatory” requirement is not desirable in some cases may be reasonable. But if the Contracting Officer does not make a change prior to your submission, it can be protested if you receive an award based on your exception to the “Mandatory”.
Most of us do not intend to be liars; but in Federal Procurement, an “Omission” can be seen as intent of “Commission.”
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