by Sarah Schauerte
As many of you may have heard, the VA’s Center for Verification and Evaluation (“CVE”) is considering an interim final rule to require firms to go through the VetBiz verification process every three years, not two. (Verification is necessary for firms interested in competing for SDVOSB or VOSB set-aside contracts issued by the VA). This is a welcome change for many, simply because the verification process is tedious and cumbersome, and it’s obviously preferable to be spared from it for an extra year.
The VA gave the following reason for the change:
“This change is appropriate because VA conducts a robust examination of personal and company documentation to verify ownership and control by Veterans of applicant businesses. In addition to verifying individual owners’ service- disabled veteran status or veteran status, in accordance with 38 CFR 74.20(b), VA reviews an applicant’s: [lists the required documentation]. Given the depth of this review, annual or biennial re-verification examinations have become an unnecessary administrative burden on both applicants/participants and VA.”
I’m all for simplifying the VA’s verification process, which has gone sharply downhill over the last few months due to new processes. However, I have to say that this isn’t the way to go. Requiring companies to go through re-verification every two years provides a needed check, as firms can go through considerable changes during that time period. This is especially true for start-up firms that speed through the verification process due to the fact that they have very little documentation to provide. After they are verified and begin building their infrastructure and performing contracts, that’s when eligibility issues arise. As such, to permit those firms to remain verified for three years undermines the integrity of the program. It also puts those firms at risk, as the verification process provides an official audit of their eligibility for the set-aside contracts they depend upon for financial viability. (As such, if anything is wrong, it can be pointed out and corrected during the verification process). Accordingly, I believe the three-year rule should only apply to firms that have already been re-verified once.
If the VA wants to simplify the verification process, how about doing away with requesting tax returns? Not only is that requirement invasive, but especially for the non-veteran business owner it is complexly irrelevant. Why on earth does the CVE need the non-veteran business owner’s spouse’s W2? The CVE states that the tax return is necessary to see where the business owners are receiving their revenue, but how is that really relevant? A business should not have to withdraw because the veteran can’t find the W2 that shows he earns $3K a year as a referee for a high school basketball team. Nor should it have to withdraw because the non-veteran’s spouse holds her W2 hostage (which, ironically, undermines the “control” the VA is so concerned with the veteran having).
What do you think? How can the CVE simplify its process? Also, if you want to comment on the new three-year rule, the VA is accepting comments through April 24. Go here for specific instructions for submitting a comment.
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