by Wayne Simpson
Small Business Contracting Goals for “Manageable Spend”
On May 25, 2017, with only 128 days remaining in Fiscal Year 2017, the Secretary of Veterans Affairs issued VA’s Fiscal Year 2017 small business goals. This is actually an improvement over when the Fiscal Year 2014 goals were issued with only 38 days remaining in the fiscal year. Fiscal Year 2014 was the last time the Secretary of Veterans Affairs issued a Small Business Goaling Memorandum.
In response to a May 24, 2017, Freedom of Information Act request for VA’s Fiscal Year 2015, 2016, and 2017 Secretary of Veterans Affairs Goaling Memorandums, VA provided a copy of the Fiscal Year 2017 Secretary’s Goaling Memorandum, along with a no responsive records response for copies of the Fiscal Year 2015 and Fiscal Year 2016 Secretary’s Small Business Goaling Memorandums. A no responsive records response can only mean the VA Secretary did not issue the annual goaling memorandum for those years.
VA’s Office of Small and Disadvantaged Business Utilization, an organizational element of the Office of the Secretary, is responsible for preparing and coordinating the Secretary’s annual small business goaling memorandum. It appears this was not done for Fiscal Years 2015 and 2016.
The VA Secretary’s Fiscal Year 2017 Small Business Goaling Memorandum makes it official: VA’s department-wide goals for Service-Disabled Veteran-Owned Small Business (SDVOSB) and Veteran-Owned Small Business (VOSB) remain at 10% and 12%, respectively. These goals have been flatlined since Fiscal Year 2010, despite VA substantially exceeding the goals each year.
VA’s failure to issue goaling memorandums for Fiscal Year 2015 and 2016, and its apparent inability to get goals established and in place prior to the beginning of the fiscal year, or immediately thereafter, is troubling. But more troubling is VA’s continued flatlining of SDVOSB and VOSB goals.
Interestingly, the VA Secretary’s Fiscal Year 2017 Small Business Goaling discusses a Fiscal Year 2016 piloted effort to concentrate on spend areas where active goals management is most likely to produce results. VA identified “manageable spend” areas based on VA-funded contract actions, but excluded major health care contracts, large-dollar major construction actions, and mandatory domestic delivery service contracts under the Federal Strategic Sourcing Initiative. Since no goaling memorandum was issued by the Secretary in Fiscal Year 2016, it is unlikely many people outside VA would have known of this change.
VA’s Fiscal Year 2017 Small Business Goals are established at the statutory level for Women-Owned Small Business (5%), Small Disadvantaged Business (5%), and HUBZone Small Business (3%). VA’s Small Business goal was reduced from 32% last fiscal year, to 28.5% for Fiscal Year 2017. The Secretary’s memorandum also establishes VA’s Fiscal 2017 subcontracting goals.
Unlike in previous years, when the VA Secretary’s Small Business Goaling Memorandum was prominently posted to VA’s Office of Small and Disadvantaged Business Utilization website, the Fiscal Year 2017 memorandum has not been posted as of June 10, 2017. A link to the memorandum is shown below.
VA’s Office of Small and Disadvantaged Business Utilization ceased posting monthly small business accomplishments around the time VA began flatlining the SDVOSB and VOSB goals. What could possibly be VA’s justification for flatlining its SDVOSB and VOSB goals since Fiscal Year 2010 and reducing transparency in this area?