It's easy to make mistakes when you don't have information. When the information you do have isn't good, things can go from bad to worse. On that note, this blog is about another piece of information it seems many in federal contracting don't have or at least don't leverage, for one reason or another.
During the most recent edition of our "No Contract Vehicles Needed" seminar (part of The ASBCs of Government Contracting™ where we discuss agency awards not leveraging established contract vehicles) it came to light that a portion of the $13.6 billion in FY13 "No Contract Vehicle" awards by Department of Energy included over $1B in contract actions where a NAICS Code was not referenced, at least not in FPDS-NG.
So I decided to poke around governmentwide to see what else I could find and, here's what I learned:
- Thirty-six federal agencies, boards and commissions have FY13 contract actions in FPDS where a NAICS Codes is not referenced.
So what's the big deal about NAICS Code not being referenced?
For one thing, the NAICS Code is the basis for how the government determines the applicable size standard for contracting direct with small business when opportunities are set-aside, and it also indicates how the contracting officer describes the principal purpose of the item(s) or service(s) being acquired in a particular requirement.
During requirements planning, agencies will often leverage a variety of resources to conduct preliminary market research to determine what types of companies are available in the relevant marketplace based on a number of factors. One of the "factors" they may use to filter search results is the NAICS Code which Industry uses to demonstrate applicable offerings for their specific entity.
Some of those sources can be industry associations, SAM.gov, the SBA Dynamic Small Business Search and more.
On a side but very related note, many companies do not have correct or enough of the correct NAICS Codes on their SAM or DSBS (for small businesses) profiles. Regularly I speak to companies who have received awards under NAICS Codes not represented on their profiles or marketing collateral. Presumably, the codes referenced in the awards are somehow related to the offerings these companies make available.
But getting back to our normal programming, there is another factor that is often overlooked known as Product and Service Codes or PSCs. These codes "describe products, services, and research and development (R&D) purchased by the federal government and indicate what was bought for each contract action reported in the Federal Procurement Data System (FPDS)." according to the PSC Manual published by GSA's Office of Governmentwide Policy. Generally speaking, a great many federal contractors are not aware of, nor use PSCs in the course of their market research, when market research is executed.
So the big deal is, if your current searches (and search agents) or SAM profile are primarily (or solely) based on NAICS Codes, here's what you are potentially missing:
- For FY13, twenty-five agencies, boards and commissions account for over $2 billion in awards.
- FPDS-NG reports 3,679 contract actions executed YTD where a NAICS Code was not referenced.
- 448 PSC Codes have been referenced in contract actions YTD where no NAICS was referenced.
- The net of product purchases is $396 million. Purchased services net is $1.8 billion.
- Of these awards, only $22 million went to small businesses.
- The prevailing Award/IDV Type referenced in FPDS is "definitive contract" which indicates awards where an established contract vehicle was not used. Over $1.9 billion of awards YTD are of this type.
- The primary Extent Competed is "Full and Open Competition" accounting for over $1.6 billion in awards.
As a point of reference, FPDS reports over $4 billion awarded this way in FY12 and the breakdown by agency, extent competed, small business awards and award type is pretty similar to FY13.
Why do I think this is useful? In the current environment, every little scrap can make the difference between success or obsolescence.
Information is power, right?
Peace.The Chief Visionary
"The person who says it cannot be done should not interrupt the person doing it."