Comments Sought: Proposed Rule To Establish Government-Wide Mentor-Protégé Program

By Sean Milani-Nia

On February 5, 2015, the Small Business Administration (SBA) issued a new proposed rule that would establish a Government-wide mentor-protégé program for all small businesses.

Under the current framework, entities that enter into joint venture agreements to perform federal contracts are, in most instances, considered “affiliates.”  In determining a company’s eligibility to compete for set-aside procurements, the SBA combines the offeror’s size with the size of its affiliated entities. Thus, an otherwise eligible small business may be deemed large due to its affiliation with another entity.

An exception to this general rule exists for participants in the SBA’s 8(a) mentor-protégé program.  Under the 8(a) mentor-protégé program, an 8(a) protégé can joint venture with an approved large business mentor without being deemed affiliated.

The SBA’s proposed rule seeks to extend the mentor-protégé program to all small businesses. The intent is to create parallel program for non-8(a) small businesses, including participants in the HUBZone, Women-Owned Small Business, and Service-Disabled Veteran Owned Small Business programs, that is identical to the 8(a) mentor-protégé program. Under the proposed rule, any small business would be able to enter into an SBA approved mentor-protégé relationship and joint venture with its approved mentor without being considered affiliated.

Expanded Protégé Definition

Note that the proposed rule would allow more businesses to qualify as protégés under both the 8(a) mentor-protégé program and the proposed small business mentor-protégé program. Currently, in order to qualify as a protégé under the current 8(a) mentor-protégé program, an 8(a) contractor must (1) have a size that is less than half the size standard corresponding to its primary NAICS code; (2) be in the developmental stage of its 8(a) program participation; or (3) have not received an 8(a) contract.

The proposed rule provides that any firm that qualifies as a small business for the size standard corresponding to its primary NAICS code would qualify as a protégé under either the small business mentor-protégé program or the 8(a) mentor protégé program. SBA proposes to remove the requirement that the small business protégé have a size less than half the size standard corresponding to its primary NAICS code.

Ownership Interest

Similar to the 8(a) mentor-protégé program, the proposed rule provides that a mentor may own an equity interest of up to 40% in the protégé. This could be a significant opportunity for small businesses that are looking to increase working capital.

If finalized in the current form, the proposed rule would create significant opportunities for the participants in the new mentor-protégé program, but could place those small contractors that do not participate at a competitive disadvantage. Contractors who are interested in participating should begin evaluating potential partners and even structuring their agreements. The SBA has recognized that once the proposed rule is finalized, the number of firms seeking SBA approval of their mentor protégé agreements may become “unwieldy.” SBA states that it may institute certain open and closed periods for receipt of mentor-protégé applications. SBA would only accept mentor-protégé applications in open periods. Contractors should be prepared to submit their applications as soon as possible to avoid missing the first open period.

Comments on the proposed rule are due on April 6, 2015.  Send your comments prior to April 6 to Federal Allies Institute Comments@FederalAllies.org 571-217-0823.

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Federal Allies News Summer Edition Pictorial

Federal Allies News Summer Edition 2014

Letter from the Executive Director

Federal Allies Institute first invited the Fort Meade Regional Growth Base Business Initiative (BBI) to participate at one of our small business conferences held at Fort Myer, Virginia in 2009 and since FAI has partnered with Fort Meade BBI involving them in several other FAI national conferences. We recently welcomed the invitation by new Base Business Initiative Director Kellyann Few to announce the Federal Allies Corporate Ethics Certification Program before 125 small businesses. FAI’s CEC program is an opportunity for small businesses to earn certificates presented by the FAI Ethics Board of Overseers chaired by Gary Shumaker, President & CEO, C2 Solutions Group of Reston, Virginia.

A new FAI relationship is underway with the Foundation for Innovation and Discovery, FINND. The foundation nurtures a community of interest around innovation, sparks conversation between technologists, and educates decision-makers and promotes an environment of non-proprietary collaboration and transparency in the discovery of innovative solutions. FAI is a FINNDER discovery engine participant for Foundation for Innovation & Discovery. FAI Board member Gabriel Fulton PMP, Founder & CEO, Sintel Group, Inc., Columbia, Maryland chairs the FAI-FINND relationship.

Of the many deserving award recipients at MBDA 2014 National MED Week Conference, Federal Allies Institute members were present to support this year’s Distinguished Supplier Diversity Award winner Diane G. Dempsey, Director, Socio-Economic Business Programs, BAE Systems Intelligence & Security. Dempsey, an integral early supporter of the Federal Allies Institute, is an individual at BAE Systems I&S whose business practices have had a significant impact on the growth and development of minority-owned firms. Dempsey’s career spans over 30 years in the procurement, subcontracts and supplier diversity fields. She’s become a leader in supplier diversity through her dedication and commitment to supporting organizations that advocate diverse suppliers, and serves as an instrument in bridging the existing gaps in industry related to small business utilization.

The FAI Oklahoma Chapter was invited to participate at Oklahoma MED Week iGNITE! Conference & Awards Dinner honoring outstanding minority entrepreneurs held in Tulsa and organized by James Ray, Project Director, MBDA Center – Native American and Alaska Native Program and REI Oklahoma staff and leadership. Keynote speaker was one of the nation’s top business thought leaders Dr. Leonard Greenhalgh, professor of management at the Tuck School of Business at Dartmouth.

With a growing number of members of the FAI Board of Directors located in Texas, the FAI Texas Chapter held several meetings during August to expand and grow the chapter’s grassroots organization within the state. Among the participants the Grand Prairie Chamber of Commerce 2015 Chairman of the Board Herb Rolph and President Lynn McGinley; and Loletha Moore, Interim Director, The Best Southwest SBDC in Cedar Hill.

Federal Allies Institute University Outreach Program has made new inroads now interacting with American University, University of Maryland, The George Washington University and George Mason University.
We welcome new members and participants. If you would like to take part in any of the above activities, please call (571) 217-0823.

David T. Boddie
Founder & Executive Director
Federal Allies Institute

Health & Human Services Secretary Confirmation Hearing for Sylvia Burwell

HHS & Federal Allies Institute have worked together since FAI’s first national conference at Fort Myer, Virginia and the Therapeutic Discovery Project Tax Credit symposium that Federal Allies was asked to organize by U.S. SBA, with Treasury, HHS and FDA.  That conference yielded small bioscience research firms of 250 or fewer staff with millions of dollars to hire new researchers and to keep U.S. research from going offshore.

President Obama’s nominee for Health and Human Services Secretary Sylvia Burwell testifies at her confirmation hearing this morning. On behalf of Federal Allies Institute, I wish Sylvia Burwell and the ability and experience she brings to office, best wishes.

David T. Boddie, Executive Director, Federal Allies Institute

http://www.c-span.org/video/?319176-1/hhs-secretary-confirmation-hearing

C-SPAN Photo credit: Carolyn Kaster, Associated Press

Letter from the Executive Director April 2014

Disaster Response & Federal Allies Institute

 

In 2005 I was thrust into the world of disaster response in Alabama as an entry level FEMA “Disaster Assistance Employee HQ” from Washington, D.C. there to help about 114,000 in the first 90 days – many were sudden, new residents of Alabama moving out from harm’s way. Many former residents of New Orleans and other coastal areas from Louisiana to Florida simply drove their cars north until they ran out of gas and the gas stations did likewise. At which point they called the FEMA 800 number for help.

Alabama’s disaster headquarters, Joint Field Office, in Montgomery, Alabama was an old Sam’s Club building leased by GSA and converted to office space and filled blue partitioned offices.

During my first week, with vaccinations and on-the-job training, I rose through the ranks of Individual Assistance to work directly for FEMA’s top Coordinating Federal Officer of Alabama and the top Alabama State Coordinating Officer to organize massive public events of resources and evacuees across the state.

Most were planned and implemented within 48-hour notice and as I worked with all the FEMA components, community and church groups, and corporate America, one that stood out was FEMA Logistics. Staffed with can-do spirit and drive, I thought to myself these guys are straight out of the helicopter boat scene in Francis Ford Coppola’s Apocalypse Now.    No logistics problem was too big or had a too brief of a time span attached. Thousands of families, massive tents, tables, chairs, psychologists, generators, water, fuel, federal security, computers, disaster recovery centers, housing, blue tarps atop of houses everywhere, people that needed immediate assistance, people too proud to accept assistance, and the list could go on for many pages. At the end, trained in many Disaster courses, I spent my first day at a Disaster Recovery Center as the manager.   Besides learning all about disasters, with even more training at Fort McClellan, my experiences with Katrina, engrained in my mind the value of companies coming to the rescue, for example, particularly Walmart with its massive distribution channels and low-key generosity.   I don’t ever remember Walmart being acknowledged for all they did.

As my responsibilities grew, I gained many experiences working with a vast network of new colleagues throughout Alabama, Texas, Louisiana, Mississippi, Florida and Congressional Relations and with FEMA headquarters, such as with FEMA Legal in negotiating housing agreements between FEMA, Department of Agriculture, and Veterans Administration. Upon return to Washington, DC I took part in federal policy meetings and hearings on how to improve the multi-agency response to such a national disaster as Hurricane Katrina. I brought my best ideas.

That brings us to our next Federal Allies Summit at Hogan Lovells, Disaster Response Summit, April 17, 2014. On behalf of Federal Allies Institute, we hope you will come to Washington, D.C. and attend. It will tell you what you need to know. Register online at FederalAllies.org. Members receive a special rate.

Sincerely,

David T. Boddie, Executive Director, Federal Allies Institute

 

Federal Allies News March 2014

Letter from the Executive Director

SBA’s New Emerging Leaders Program: StreetWise Steps™ to Small Business Growth

U.S. Small Business Administration’s Emerging Leaders initiative has asked Federal Allies to publicize the agency’s search for CEOs of established small businesses to enroll in a free evening program to help grow revenues and jobs.  Twice monthly, 13 sessions, 40 classroom hours currently planned for 27 cities.

Requirements include three years in business, two or more employees, annual revenue $400,000 to $10 million, and DBEs or lower income census track.

Module 1: Business and Strategy Assessment. Module 2: Financials. Module 3: Marketing and Sales. Module 4: Resources- People, Accessing Capital and Government Contracting.  Module 5: Putting it all together – Strategic Growth Plan Presentations.

Contact your local district office.  More information is available online at sba.gov/emergingleaders or you may e-mail SBA@FederalAllies.org.

A Brief History of Federal Allies and SBA

Federal Allies Institute was launched during National Small Business Week 2008, the U.S.A.’s top small business recognition program and organized by the U.S. Small Business Administration.

The mutually beneficial relationship between Federal Allies and SBA has quantifiably helped small businesses.  For example one project included SBA’s request for a free biotechnology grant application seminar, organized by Federal Allies that helped enable 26 research firms to each receive one or more grants of $244,000.  In addition to SBA, the grant process included the U.S. Department of the Treasury, U.S. Department of Health and Human Services, and U.S. Food and Drug Administration.

Several top biotechnology associations, including BIO, were recruited to serve on panels of the Federal Allies event.

Welcome New Members

Welcome Distinctive Home & Health Care! The Distinctive Home & Health Care 1st Annual Heart Disease Awareness Networking Event held at Distinctive Home & Health Care’s Corporate Office. (L to R) Deborah Guynn, President, Jim Guynn, Vice President, Regina L. Singletary, Executive Assistant, DHA Acquisition Management & Support, and Chante Davis, Director of Operations. Guests enjoyed delicious appetizers with wine provided by Kathy Gaines. A fundraiser for research, guests received copies of USDA 10 Tips to Be Active Adults  and Affordable Care Act Sign Up Locations for Residents of Montgomery and Prince George’s Counties, in Maryland.

Federal Allies Institute Corporate Ethics Certification Program Underway

The Winter Sessions of Federal Allies Institute’s Corporate Ethics Certification are being held during February and March.  A second program planned for the Spring is currently seeking enrollees.  The fee for members is $1,000 and non-members $1,500.  The Federal Allies Institute Scholarship Program offers a limited number of partial scholarships.  The Federal Allies Institute Board of Overseers for the program seeks to expand.  Recent meetings to publicize the program have been held including with U.S. Senators Mark R. Warner and Tim Kaine, both of Virginia, the home state of the Federal Allies Institute.

Sincerely,

David T. Boddie

Executive Director, Federal Allies Institute

Federal Allies Institute Interview: Kevin D. Freeman, New York Times Best-Selling Author on Economic Warfare and Cyber

Federal Allies  Recently, the Russia invasion of the Crimean peninsula utilized both conventional and cyber attacks.  In your latest book Game Plan, you outline the potential threats against the U.S. economy and how Americans can be prepared to protect their savings and investments.  In other words, what Americans see as the marketplace, our enemies now view as the battle space to include cyber economic attacks for a global economic war.  You have written several books on the subject.  Can you enlighten us on your federal agency meetings and what has been their response to the potential for economic warfare and cyber attacks?

Freeman  It is important to understand that the critical issue is economic warfare and cyber is a powerful way to conduct that war. Without understanding that the war is economic, cyber becomes a catch-up battle with malware, viruses, and hacking—something for which you might install some good defensive software but not create a threat doctrine.

Most of my meetings have been with Defense and Intelligence agencies. Initially, the meetings were based on curiosity as the concept of economic warfare and financial terrorism was viewed as outside the mainstream of discussion. In one case, a group was convened to determine how offensive weapons could be deployed using financial strategies.

In most cases, after the meeting, there was a general acknowledgment of the threat but little willingness to address it. “It’s not in our lane,” was a common response. In other cases, there seemed to be a denial of the entire concept. “No one would be able to do that,” and “why would anyone harm our economy when they would be hurt in the process,” were typical responses. Since 2008, I have met with a dozen or so different Pentagon-related offices, top leadership (past or present) from three different intelligence agencies, various appropriators, Federally-funded research labs, and others.

Over time, with further revelations, however, the idea of economic attacks, especially cyber in nature have gained critical acceptance. I recall a meeting at the FBI, for example, where the whole idea of attacking our financial system was ridiculed. A couple of weeks later, the NASDAQ was hacked and it was acknowledged that the resources behind the breach leaned more to nation state that criminal organization. And, there have been directed threats by Putin against our markets and currency, the flash crashes, and other incidents that support my general thesis that the next war is economic with cyber weaponry. Then, there were the revelations from Juan Zarate in his book, Treasury’s War that acknowledged not only that we had developed economic weaponry to use against terrorists but also that we were vulnerable to a host of financial attacks.

Unfortunately, the problem remains that the broad issue of economic warfare and financial terrorism, despite its serious nature, doesn’t “belong” in any one location and may not reside anywhere. We are looking at cyber, but unless we see it in the context of economic warfare we won’t address it properly. Outgoing head of the NSA, General Keith Alexander acknowledged our vulnerability in a 60 Minutes interview (as excerpted from Forbes December 15, 2013):

“On the CBS program 60 Minutes tonight, National Security Agency (NSA) director Gen. Keith Alexander admitted that ‘a foreign national could impact and destroy a major portion of our financial system’ by placing a virus in our computer systems ‘and literally take down the U.S. economy’ if the virus was spread around … While mentioning known attacks by China, Deborah Plunkett, another NSA official spokesperson, told CBS: ‘Don’t be fooled. There are absolutely nation states who have the capability and the intention to do just that,’ i.e. ‘literally take down the U.S. economy.’”

Federal Allies  How big of an issue is cyber in comparison to all other concerns?

Freeman  Our potential enemies have cyber as the #1 means of future warfare.  That says something. It is likely that all future conflicts will have at least a cyber component. The risk is, with cyber or EMP or other attacks that Pearl Harbor and Hiroshima could be combined into a single event. There are sovereignty ending risks if the electric grid is wiped out, or the financial system completely collapses. Consider this from Wired Magazine in 2010:

“Cyberspace has become the fifth domain of warfare, after land, sea, air and space. Some scenarios imagine the almost instantaneous failure of the systems that keep the modern world turning. As computer networks collapse, factories and chemical plants explode, satellites spin out of control and the financial and power grids fail.”

The Russians used cyber attacks both in Georgia and more recently the Ukraine. China, Iran, and North Korea, and multiple terror groups/international criminal organizations have all developed sophisticated cyber units as a primary means of war fighting. They are testing and probing our systems daily.

Federal Allies  The Defense Department named cyberspace a new domain of warfare in 2011. Today, U.S. Cyber Command, the services, and U.S. partners and allies are working together to make that inherently collaborative, adaptable environment a suitable place for military command and control.  Which federal agencies are leaders on cyber?

Freeman  DoD through Cyber Command and NSA and Homeland Security are key leaders, with significant cyber efforts at FBI and throughout the Intelligence Community. I am concerned, however, that the effort isn’t fully integrated as would be required to develop an economic war footing. It’s a little like pre-9/11 when anti-terrorism was split across a variety of efforts with little coordination or cooperation.

Federal Allies  Which published government reports do you recommend would bolster our readers?

Freeman  All of my work has been through existing contractors. I recommend my DoD reports, my books, and blogs with info at http://secretweapon.org.

Federal Allies  As you look across the agencies, who is leading the most important initiatives underway?

Freeman  From my limited vantage point, DoD has shown the most interest which is appropriate as this is an economic war with a cyber dimension.

Federal Allies  What would you like to leave our readership thinking about?

Freeman  I believe we are potentially facing a third World War fought primarily through economic means. Most prospective enemies of the United States would prefer not to match our kinetic weapon systems. But, they view our underlying strength coming from our economy and our economy appearing vulnerable. Unfortunately, our nation tends to prepare for the next war based on the weapons from the last war. This is a mistake. It is critical that we develop a complete economic warfare doctrine and build integration for key cyber efforts to that doctrine.

Federal Allies  Thank you.

 

Read Federal Allies News March 2014 edition: Economic Warfare and the Use of Cyber. An in-depth interview of New York Times Best-Selling Author Kevin D. Freeman. www.FederalAllies.org  Interview conducted at CPAC and online.

@FederalAllies Interview with Kevin Freeman (March, 2014 Issue): secretweapon.org/federal-allies… #GamePlan