FedSubK Feature: What To Know Before You Say Go (or No-Go)
The day has come…the Request for Proposal (RFP) you’ve been watching and waiting for has gone “live.” Your team has made a tentative decision that it wants to submit a proposal for this project. You download the solicitation documents and start looking through the requirements. Contract type, type of work, is subcontracting or limitations in subcontracting required, terms, conditions, pricing…you run down all the key pieces of information that you need to form your risk tolerance decision for the work. But, there are some other key pieces of information that, from a former Contracting Officer and Source Selection Authority’s perspective, to also keep in mind as you make your final “go/no-go” decision to propose and develop your proposal.
Know the Rules for Government Exchanges with Industry Before Receipt of Proposals (FAR Subpart 15.201)
Exchanges of information between the Government and Industry are encouraged. However, any exchange must be consistent with the procurement integrity requirements of FAR Subpart 3.104. This includes not only exchanges but also disclosure, protection, and marking of contractor proposal information and source selection information.
Requests for Information (RFIs) and Draft RFPs for industry input are considered part of the market research process under acquisition planning. These methods are not required but when used allow for more open exchanges between the Government and Industry. Potential offerors can share information to influence the Government’s procurement strategy (but mark anything proprietary accordingly). The Government may also hold conferences or meetings for the purpose of obtaining industry input. Recently one agency did an oral RFI exchange with industry and I was skeptical of how it would go but was pleasantly surprised at how Government posed the questions live and how industry responded (or didn’t when the line that led to exchange of proprietary info was near crossing). (See even an old dog can learn new tricks!)
Exchanges after issuance of the solicitation but before receipt of proposals are used by the Government to improve potential offerors’ understanding of requirements and allow them the chance to determine their ability to meet those requirements. These exchanges often take the form of questions from industry on RFP documents, answers in response from the Government, and pre-proposal conferences. The Contracting Officer oversees and controls these exchanges. If you get information from another source—a team member or someone other than the Contracting Officer—proceed with caution and verify, verify, verify.
Watch for Amendments! (FAR Subpart 15.206)
Changes to the RFP documents are made by formal amendment to the solicitation before the established time and date for receipt of proposals. Amendments must provide sufficient time for potential offerors to digest changes and update proposals. Each amendment will also be announced with its own notice and published in the Government Point of Entry (GPE), typically SAM, GSA eBuy, or other agency portal used to publicize opportunities. Amendment notices will outline the changes made. An oral notice may also be used when time is of the essence, such as the case may be in a contingency or emergency environment, which is then formalized by a written amendment issued by the Contracting Officer.
More often than not, the Government provides answers to RFP questions that may or may not be material in nature or result in an amendment. The Government doesn't always tell you if an amendment is forthcoming either. If in doubt, ASK. Don't wait for an amendment and then ask for a proposal extension later; not likely to happen. Instead put it in your rhythm to ASK questions like this as soon as they come up. Don't make assumptions!
Amendments can also be issued after the close of receipt of offers/proposals. However, if the Contracting Officer determines that such an amendment “...is so substantial as to exceed what prospective offerors reasonably could have anticipated so that additional sources likely would have submitted offers had the substance of the amendment been known to them”, the Contracting Officer must cancel the original solicitation and issue a new one, regardless of the stage of the acquisition.
The worst possible thing is to finish an offer/proposal and realize too late that you haven’t taken an amendment into account. Failure to acknowledge an amendment is grounds to eliminate your proposal from consideration right out of the gate!
Understand the Basics of Different Source Selection Techniques (FAR Subpart 15.1)
Techniques for the selection of sources under competitive procurements fall within a range called the Best Value Continuum. This range equates to the Government’s perceived risk of unsuccessful performance which is then translated into the prioritization of technical factors and cost or price factors and their individual and collective importance.
An agency may use only one or a combination of the Tradeoff Process and the Lowest Price Technically Acceptable Process to arrive at the determination of the best value for the Government. The characteristics of each are found in the table below.
Tradeoff Process
Lowest Price Technically Acceptable Process
Allows selection of other than the lowest-priced or highest technically rated offeror using tradeoffs between technical superiority and cost or price, as described in the solicitation.
Requires selection of the technically acceptable proposal with the lowest evaluated price
The technical factors and significant subfactors that affect contract award and their relative importance are disclosed in the RFP.
The RFP also includes a statement whether all evaluation factor factors other than cost or price (aka “technical factors” when combined, are–
- Significantly more important than cost or price,
- Approximately equal to cost or price, or
- Significantly less important than cost or price.
Technical factors are not ranked by relative importance.
Failure of a proposal to meet the minimum technical acceptability standard of any technical factor or subfactor automatically eliminates the proposal from further consideration.
Past performance is a required evaluation factor.
Past performance is not a required evaluation factor.
Factors and significant subfactors establish a list of criteria describing required or desired skills and experience against which the proposal is subjectively evaluated.
Factors and significant subfactors establish objective thresholds of technical acceptability (measures) against which the proposal is evaluated.
Technical ratings are subjective and use a rating scale of adjectival descriptors, colors, numerical weights, or original rankings. Cost or Price is evaluated, not rated.
Technical ratings are objective and use a go/no-go, pass/fail, or acceptable/unacceptable scale. Cost or Price is evaluated, not rated.
Provides the greatest flexibility for the Government to achieve the best balance of technical and cost/price acceptability.
Provides the ability to achieve a minimum technical acceptability level on all technical factors and significant subfactors and achieve the lowest evaluated price.
Any perceived benefits of a higher-priced proposal require supporting documentation to quantify the payment of any additional cost in terms of specific benefits to the Government.
Only the lowest-priced proposal of the proposals found to be technically acceptable is considered for award.
The point-by-point tradeoff decision is documented and reviewed as required by FAR, any agency FAR supplement, and agency policy.
Tradeoffs are not allowed.
Award Without Discussions or Competitive Range? (FAR Subpart 15.306(c))
The Government has a choice. It can choose to make a contract award decision based solely on initial proposals and not engage with offerors, or it can establish a competitive range to conduct discussions (aka, negotiations) before an award is made.
What’s a competitive range? Based on the ratings of each proposal against all evaluation criteria, the Contracting Officer will establish a competitive range comprised of all of the most highly rated proposals; those most likely to receive the contract award. It’s a down-selection. The competitive range can be further reduced for purposes of efficiency when documented with the rationale why and the solicitation so states.
The solicitation will disclose the Government’s choice. This choice is important. An award without discussions means you get one shot – the first shot – to get your proposal right. There are no fixes or changes allowed later. However, even when the Government chooses “award without discussions,” it always reserves the right to open discussions with offerors if it is in the Government’s best interest to do so. But don’t rely on it happening. If the Government can avoid discussions before the award, it will; trust me on that. It saves weeks of work and documentation when discussions are avoided. Write your best offer/proposal the first time!
When developing your go / no-go decision matrix, add these elements. Depending on your current risk tolerance, you’ll feel more confident that you’ve covered the bases procedurally as well as technically when making that important decision about expending resources for offer / proposal development.
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FedSubK Feature: Be Seen! Why Your SBS Profile is So Important
UPDATED November 2025 to incorporate changes from the SBA Dynamic Small Business Search (DSBS) to the new SBA Small Business Search (SBS)
I’ve posted on LinkedIn a lot recently about ways to be seen as a little fish in the big pond that is the Federal marketplace. Every GovCon consultant has a take on the best entry points with agencies. My take is there is only one place small businesses MUST put their best foot forward to be quickly and easily seen by Federal buyers for potential opportunities and influence small business set-asides.
The Small Business Administration (SBA) Small Business Search (SBS) is THE PLACE you must be on your A-game.
The Small Business Search (SBS) is a database in which SBA houses information on the current pool of certificated small businesses. Presently, small businesses that do not have certifications or are self-certified, may also create a profile in this database. The SBS is used by contracting officers, small business specialists, large prime contractors, and other small businesses looking for teaming partners to find small businesses that can help meet Federal requirements and identify businesses that can help the Government (or a prime contractor) meet its small business goals. SBS is one of the first--and often only--sources used in market research by agencies to determine the numbers of small businesses able to provide products or services by North American Industry Classification System (NAICS) code.
You can see why this might be an important place to pay attention to, eh?
Businesses have forgotten about the SBS in the last few years because SAM.gov no longer sends small business registrants directly to SBS at the end of their registration to complete the profile like it used to. I HUGE bummer. Businesses now must wait for their SAM.gov registration to be activated, then they can establish an SBA SBS account, claim their entity record, and fill in their company profile in the SBS system. Federal buyers are looking for detailed information from SBS to use as part of their market research efforts.
SBS isn’t only for market research.
Even more importantly, the SBS shows Federal buyers the status of any pending certification applications for the purpose of determining whether you are eligible to compete for a set-aside action. For example, an Economically Disadvantaged Woman Owned Small Business (EDWOSB) can still submit an offer for an WOSB set-aside even with a pending application for certification showing in the SBS. Contracting Officers often use SBS as a source to confirm the socioeconomic certification status and 8(a) program participation along with SAM.gov.
While MySBA Certifications automatically sends socioeconomic certification status to SAM.gov and updates the requisite reps and certs to reflect the correct socioeconomic status, recently it has taken weeks for that migration to occur. WOSBs and EDWOSBs have reported not seeing their correct socioeconomic status reflected in their SAM entity record.
Businesses should always check their SAM entity record to ensure that the proper status is shown within a reasonable time after receipt of an active certification status; usually within 14 business days. If the record is not accurately reflected, you can contact answerdesk@sba.gov or the SBA socioeconomic program under which your business was certified for assistance. If a Contracting Officer says that your SAM record does not reflect the status claimed, ask the Contracting Officer to check SBS for the more accurate information because of these delays.
So now let’s talk about BEING SEEN in SBS and walk through each part of the registration.
Understanding how to maximize the fields in SBS is how you can make the best possible first impression so that Federal buyers want to learn more about YOU!
The Key Words
Often businesses pluck these from thin air and over-generalized based on what they think the Government wants to see. Key words need to reflect and incorporate aspects of your primary NAICS, secondary NAICS, and what you can provide under those NAICS. If you use key words that don’t reflect your primary NAICS, you’ll leave the Government scratching their head about you. They won’t understand the message you’re sending about your company. Be consistent and specific with key words while tying into your NAICS codes in order to leave the best impression. You have 500 characters -- use them wisely.
The Website
Be sure that you include the URL for any website you have. Make it be more than a landing page. It needs to tell your story. It needs to include information about your company, what you sell, past customers, and products or solutions you provide. And most of all, it must be polished. Scrub your site hard for formatting, typos, grammatical errors, etc. Acquisition personnel using the SBS will often quickly click on the site to see just how polished it is. When it looks good, they get the impression you know your stuff and pay attention to details.
The Capabilities Narrative
This is the written equivalent of your elevator pitch. This section should include all the things you’d include in that two-minute speech. Hit hard on what your company specialized in and its core product or service areas. Show the business’s focus and avoid being all over the map by overpromising on the breadth of work the business performs.
Near the end of the capabilities narrative, list any socioeconomic certifications Why not lead with it? Because that certification is only part of your business, and it alone does not get you interest from the Contracting Officer. End with that information so the Contracting Officer can easily see it in a quick query and get your business into their market research counts.
Lastly, identify any government contract vehicle or GSA Schedule your company may hold. If you can catch their eye that you have an existing GSA Schedule or your business participates in the 8(a) program, you’ll get counted and likely get a look in terms of the Contracting Officer wanting to know more. If they need to meet a socioeconomic goal, they can see quickly. You’re helping the Contracting Officer do their job. They LOVE that! (And made another great first impression!)
SBS now also includes a field to add a link to your online capabilities statement. Use it!
“Extras” You Should Never Skip
Performance History
I cannot say this enough…if you history doing work for any Government or quasi-Government entity at any level -- Federal, State, or Local level -- list them! Don’t play the “they’ll see that when I propose” game. Showing performance history—even if it is minimal or commercial and not Government--helps. How? It proves the viability of the business and the size and types of projects you’ve completed. Those goes a long way to determining eligibility of the business based on performance on same / similar work of a same / similar dollar value (“Rule of Two” stuff – you can read more about that here).
Review Your Profile
Go out to the SBS site and use the filters for your NAICS, business name, geographic location, and business types. Make sure your show up and see how your profile measures up to your competitors. Look at their records and see what they included that you haven’t. Use the good ideas of others, but don’t plagiarize. Contracting Officers will see that and that won’t look good for either of you.
Keep Evolving
Your SBS isn’t something that you can just set and forget either. Make reviewing your profile in SBS something you do when you renew your SAM.gov registration every year. If something major changes in your business focus, NAICS, or socioeconomic status, make associated changes in SBS.
What GovCon doesn't always talk about -- The SBS Influence
When doing market research and trying to determine if an acquisition should be set-aside for small businesses, the Government is not only counting about the numbers of small businesses that claim they can do the work under a NAICS code in SBS. They are analyzing your SBS profile to see if your business could be one of the "... two or more responsible small business concerns that are competitive in terms of fair market prices, quality, and delivery" and they have “…a reasonable expectation of obtaining an offer…” from you. (There’s that pesky “Rule of Two” again.)
In other words, based on what they see, could you submit a proposal likely to win? And how does a Contracting Officer determine that? Simply put... the your answers to everything we just covered.
Completing your profile helps tip the market research scales toward a small businesses set-aside and possibly a specific socioeconomic set-aside. If you're all over the map in your SBS narrative, the Government will not consider you viable eligible contractor towards that “Rule of Two” and could possible choose to go another way with their acquisition strategy, away from a small business set-aside. Or worse, they set it aside but remember your name from the market research as one of the businesses that didn’t make their initial market analysis cut.
Influence where you can! SBS is the place where you have a lot of influence!
Have I convinced you to get out there and create or update your SBS profile yet?
While the system is no longer got the word "Dynamic" in the title, don't forget its meaning. Life is dynamic, business is dynamic, and your SBS profile should still be dynamic, too. Get it completed ASAP. You can’t afford not to.
Remember again, SBS IS WHERE FEDERAL BUYERS GO TO FIND SMALL BUSINESSES and where other small businesses go to find teaming partners and subcontractors.
Get out there, GET NOTICED, BE SEEN, and STAY DYNAMIC!
(former title: FedSubK Feature: Be A Dynamic Small Business!)
Ask for the Meet and Greet. Make the Phone Calls.
I sat in on a session yesterday where another GovCon was talking about watching SAM for opportunities. But if you are doing that, you are going to be too late, unfortunately. Small businesses must start ahead of any opportunity announcement and connect with agency personnel early, before the opportunity is announced in order to be known and help shape future acquisition strategies. It got me thinking about my days as a Branch Chief and Chief of Contracting and the small businesses I know that are still flourishing today.
One particular company stands out. They were a new 8(a) firm that asked for a meet and greet. They had no federal work but showed a level of understanding about our mission that made an impression. While our acquisition strategies were in place already for the end of FY run of award, I told them I'd keep them in mind new projects crossed my desk. Every month, without fail, I would get a call or a quick drop in chat from this 8(a) to say hello and briefly inquiry about any possible upcoming projects. During one of the in-person chats about a year after our first meeting, our chief estimator popped his head in my office quickly to apologize for a few late government estimates. He said he was going crazy with end of FY and lack of staff. The 8(a) took the opportunity and said, "We can help with that." While it wasn't ideally the work the 8(a) was looking for, that simple pivot and flexibility, along with the relationship building done to that point, led to a small 8(a) sole source contract for cost estimating support. It was their first federal contract. That small contract quickly turned into a much larger 8(a) sole source contract for the same work that reached its max capacity 18 months earlier than anticipated. That led to 8(a) contracts for environmental the work the company ideally wanted, then graduation from the 8(a) program, and successfully competing on SB set-asides throughout the region and getting their own (successful) GSA Multiple Award Schedule contract.
Ask for the meet and greet. Make the phone calls. This former CO is here to tell you that acquisition personnel and SB Specialists EXPECT to hear from businesses. Large businesses aren't shy about calling (trust me). They may not be able to tell you much, but the relationship building and continual reminder that you know what they are looking for and can fill a niche--even when it's not your first choice of work--is KEY.
Small businesses must start ahead of any opportunity announcement and connect with agency personnel early, before the opportunity is announced in order to be known and help shape future acquisition strategies.
FedSubK Feature: What is Buying In?
"Buying in". Do you know what that is? Let's illustrate it with a little story...
Once upon a time an agency leader🤴 was looking around at things to make 🌟efficient.🌟 They got the idea that every agency should have the same widgets🔅 their agency had.
The agency leader🤴 called up a widget company👩🔧 and said, "We are interested in your widgets. 🔅What kind of discount can you give us?"
The widget company👩🔧 offers a discount 📉 because they know this agency🤴 not only buys for themselves but may buy for other agencies🫅🤴👸 where a highly trusted widget competitor👨🔧 presently has the work.
The widget company👩🔧 was "buying in" -- offering unrealistic discounts📉 that made the price unrealistically low not only for the current effort but also to influence the purchasing decisions on future buys. Then prices usually up 📈 again over time.
Depending on when "buying in" happens there could also be questions related to compliance with the Competition in Contracting Act (CICA) and possible other violations.
This is why agency announcements that management has made a deal for "$1 a license" and other such management interference is of concern. 🚨 Management plays the numbers game. I'm not saying numbers aren't important, but let's just say... there is a real reason why management typically does not hold contract signature authority. 😬😉
The Government is supposed to keep things fair and do its due diligence. But it's falling for the oldest trick in the book.
Risk, intent, compliance with statutory requirements, misunderstanding of requirements, and comparable market pricing must be evaluated when the Contracting Officer has reason to believe a proposed price is unrealistically low price. But are they?
If a contract isn't in place, there there is still a need to follow appropriate competition rules before a handshake deal. If a contract is already in place, there are things to consider when new discounts appear to be unrealistic including the risk of continued performance, depending on the type of product or service being purchased.
The Government gets a quick win to lock in a low rate, saving some money now. That's called the short game. Government buyers getting blurry-eyed over unbelieveably low prices and don't do the long-term analysis.
But I'll bet you a dollar the company is playing the long game. They are watching and waiting, getting to know your needs and asking loads of questions. "When do you use my widget most?" "Who buys the most widgets?" "When do you typically buy widgets?" And then as fast as they dropped the price, they raise it again on you when you can't afford to make a change -- like at an end of fiscal year. That's how they get locked in and receive perpetual contracts.
BTW...the fairy tale above is a true story. I've had new politicals and new leadership / commanders trot companies into my office saying "Company ABC here says they want to sell us "widgets" at a huge discount compared to what we're paying or others are paying now."
Well...okay then.
As a Contracting Officer, whether I could even begin to entertain that idea depends on several things. It's not an automatic "yes". You could replace "widgets" with just about any product or service and it's probably happened to a Contracting Officer somewhere. Especially as new Administrations come into Government.
The stories in the news that made me think -- "Huh, are they buying in?" are the Axios story "Anthropic wants to sell Claude to the Government for $1". (https://www.axios.com/pro/tech-policy/2025/08/05/ai-anthropic-government-sale-dollar) and FedScoop story "Federal agencies can buy ChatGPT for $1 through GSA deal" (https://fedscoop.com/openai-chatgpt-enterprise-federal-government-gsa-deal-general-services-administration-anthropic/).
My husband (also a retired Contracting Officer) and I look at each other often during the news now and, based on the reported discount or price alone, we know that company is likely "buying in". That's based on our combined 72 years of Fed experience and our Contracting Officer "Spidey sense" from having been around the block a few times. But these deals just the most recent in a series of deals GSA is making with companies since the new Administration came to town. OneGov is the program GSA is, in my former Contracting Officer opinion, using to tout savings under for the press releases. But it may come back later to be a big mistake. I hope I'm wrong.
Program/Project Managers and Contracting Officers AND the competition to these companies...LEARN about it and WATCH for it. It's on the rise.
(And don't get me started on having to argue with new politicals, leadership, and commanders about why I can't terminate a current contract and then turn around and give the same work to another contractor at their unrealistic lower price.🙄😱 That's a topic for another time.)
The practice of "buying in" is becoming more common now. Learn about it and how to spot it.
