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CVOBlog: To Be or Not To Be (a Small Business)? That IS the question!

Monday, June 21, 2010   (0 Comments)
Posted by: Chief Visionary Blog (
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Honestly. Can you give me a break?

A friend tells me to take another gander at the Washington Technology Top 100 list, specifically the group of 'small businesses' that made the list, and to let them know what I see. Not only do I see the usual round-up of Alaskan Native Corporations on the list (no comments from the peanut gallery!), but I see several companies on the list that to my knowledge don't meet ANY definition for being a small business.

I mean seriously folks, two of the companies on the list are clearly 'other than small business' which is the technical definition for companies that have the word "No" on their CCR profile under the heading of "Small Business" and "Emerging Small Business" in the section titled "Small Business Types."

Pretty simple.

Other companies on the WT Top 100 list of small businesses have added lots and lots of manufacturer NAICS Codes (which are measured in number of employees over a three-year average) to their profiles so there are affirmative responses co-mingled with the "NO's" in that same "Small Business Types" section.

Essentially, they find a few NAICS Codes that will identify them as a small business (even if the definitions don't pertain to their actual business) and assume that means they are a small business across the board. It's their own rendition of Code-Shopping with an industry twist.

Then there are those who simply did not update their revenues in CCR so that a company that advertises government sales in excess of $100M on the WT Top 100 list shows up in CCR as a company that meets the $25M size standard.

What about the one's who are not including the totals of their affiliates?

So let's say the companies who embellished their "capabilities" in CCR actually are manufacturers of... well whatever. Is that their primary industry?

In these cases, methinks not.

In the Code of Federal Regulations (CFR's) there is a section that talks about "How does SBA determine a concern's "primary industry”?" (CFR § 121.107) that states:

"In determining the primary industry in which a concern or a concern combined with its affiliates is engaged, SBA considers the distribution of receipts, employees and costs of doing business among the different industries in which business operations occurred for the most recently completed fiscal year. SBA may also consider other factors, such as the distribution of patents, contract awards, and assets."

I find it appalling that a company with more than $150M in sales to the government feels they are still in need of Government Contracting Assistance from the U.S Small Business Administration. That is what it means when you claim to be a small business, right? Keep in mind the totals listed on the WT Top 100 List only represent government sector sales and NOT total company sales.

So, what IS the question Washington Technology asks on the submission forms for the Top 100 that so confuses folks in mid-tier and large companies that they keep checking "Yes" to being a small business?

It has to be an honest mistake. Right?


Guy Timberlake
Chief Visionary and CEO

The person who says it cannot be done
should not interrupt the person doing it.

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