In this issue we continue our exploration of big Public Sector happenings that occurred at the end of 2022 and how they will affect the way we do business in 2023.
There were 5 major fourth quarter changes:
1. NCPA was acquired by OMNIA Partners!
2. The Air Force awarded their systems contract to 6 manufacturers!
3. VHA IDIQ opened up for new products to be added.
4. Packaged Office program went from letter of supply to CTAs .
5. The U.S. Small Business Administration (SBA) has terminated a class waiver of the Nonmanufacturer Rule (NMR) for multiple NAICS codes.
Again, I am sure this is not EVERYTHING that happened, but these are the ones that I think we need to address the obvious questions, “So, what does this mean for me?” and ,“How do I take advantage of these changes?” In the last issue we addressed the first three of these so refer back to that in the archives if you missed it! This issue we will address #4 and #5 on this list both of which have a large impact on those who do business on GSA contract. There was what was perceived as a minor change to the Packaged Office Program that has major impact and then SBA’s changes to the NMR waiver. If you are a small business manufacturer these are both changes that should benefit you!
Packaged Office Program now using CTAs instead of LOSs
Changes to the Packaged Office Program are now in place and require Teaming Agreements (CTAs) as opposed to the old Letter of Supply’s (LOS.) This is a big change on a couple of levels. First, it means the POC holders will only be reporting their sales, which if you are a dealer will only be services- this will definitely shake up the rankings on the SSQ (FAS Schedule Sales Query Plus) reporting.
Secondly, if you are a POC holder make sure you are paying attention to small business set asides and the requirements per the FAR. CTAs make everyone a prime and this will require more small business manufacturer participation on POC opportunities- anywhere where 51% to 100%!
SBA termination of the class waiver of the NMR
Sometimes, even for me, it is easier to just share it in their words and make some highlights. This is an excerpt from an email received from the SBA:
Effective immediately, the U.S. Small Business Administration (SBA) has terminated a class waiver of the Nonmanufacturer Rule (NMR) for the following:
Furniture Frames and Parts, Metal, Manufacturing under North American Industry Classification System (NAICS) code 337215 and Product Service Code (PSC) 7195;
Furniture Frames, Wood, Manufacturing under NAICS code 337215 and PSC 7195;
Furniture Parts, Finished Plastics, Manufacturing under NAICS code 337215 and PSC 7195;
Furniture, Factory-type (e.g., cabinets, stools, tool stands, work benches), Manufacturing under NAICS code 337127 and PSC 7110;
Furniture, Hospital (e.g., hospital beds, operating room furniture)Manufacturing under NAICS code 339113 and PSC 7195;
Furniture, Laboratory type (e.g., benches, cabinets, stools, tables) Manufacturing under NAICS code 337127 and PSC 7195.
As the above-identified class waiver is terminated, small businesses will no longer be authorized to provide the product of any manufacturer regardless of size on the identified items, unless a Federal Contracting Officer obtains an individual waiver to the NMR.
If you are a small business dealer/reseller offering product(s) from an “other than small” business manufacturer, you will need to submit a Delete Product(s)/SIN modification in accordance with MAS Modification Guidance to be in compliance with the SBA's regulations.
What does this mean and how does it benefit the small business manufacturer? If you were using this NAICS code in the past for any reason, but specifically to avoid using small business manufacturers, your luck just ran out unless you get them to give you an individual waiver per project. There are quite a few 8a’s that specifically used NAICS 337215 due to this waiver and it allowed them to pull through large manufacturers even if it was a small business set aside. This change is great news for the small business manufacturers as it should mean more opportunity in 2023.
I hope you agree this allows for more opportunity for small business manufacturers as we head into the busiest time of the year for Federal contracting. If you are not already, you should be wrapping up your sales and marketing plan for Federal and getting ready to implement in order to take advantage of the heavy spending season we are about to enter into. Best of luck to everyone!
ABOUT MICHELLE WARREN
Founder, President - Catalyst Consulting Group
Michelle Warren is President of Catalyst Consulting Group, a firm specializing in providing strategic solutions to the commercial furniture industry to enhance their sales, positioning, and distribution. With 25 years of industry experience on the dealer and manufacturer side of the industry, Michelle has been recognized as an innovator in selling to the Federal Government, State/Local Government, Higher Education and Cooperative Purchasing. Her expertise includes: sales strategies, strategic planning, 3-5 year road mapping, targeted marketing plans, distribution development, hiring reps, and training for reps and/or dealers. Michelle is known as a “serial networker” in the furniture industry and enjoys meeting people and making connections happen. If you’re interested in connecting - reach out at: Michelle@strategic-catalyst.com, connect on LinkedIn or visit www.strategic-catalyst.com to learn more about her work.
As seen in Delve | February 2023 V.35