OMB Issues New Guidance on Category Management with Interesting Provisions Regarding Small Business

By: Christine V. Williams on 04/10/2019

On March 20, 2019, OMB issued new guidance on Category Management with interesting provisions and implications for small business.  Acknowledging that SBA does not have a vote at the Category Management Leadership Council, the OMB used other methods so the SBA will hopefully have a voice in the discussion.  Additionally, in a footnote (fn. 31, page 28) OMB seems to say once a contract is 8(a) the SBA has to release it before it can go onto any federal schedule (category management).  This has always been the SBA rule, but as many 8(a) firms recognize, agencies have not always known or followed this rule and the after-the-fact discovery of the 8(a) contract leaving the 8(a) program does not cure the harm.  Here are some interesting excerpts starting at page 29:


i) Small business representation. An official designated by SBA shall serve as a non-voting
member on the Category Management Leadership Council (CMLC). This representative
shall keep the Council apprised of ideas for growing small business participation at both
the prime and subcontract levels for common spend, including progress in addressing the
actions in this subsection. In addition, OSDBUs and small business directors or members
of their offices shall be invited to participate on interagency category management teams.
ii) Baselining. BIC solution owners, working with the category managers, shall ensure that
baselines are established for Government-wide solutions, existing BICs, and solutions
being considered for BIC designation to maintain and grow small business participation.
Separate baselines shall be established to track participation of small disadvantaged
businesses, women-owned small businesses, service disabled veteran-owned small
businesses, and HUBZone small businesses, in addition to participation of small
businesses generally.
iii) Small business prime contracting strategies. The following strategies shall be pursued to increase small business contracting at the prime contract level:
• Prior to creating new or renewing Government-wide or BIC solutions, category
managers and prospective BIC solution owners are expected to work with SBA and
OSDBUs to evaluate the feasibility of creating a set-aside vehicle, either as the sole
vehicle or in parallel to the establishment of an unrestricted vehicle, as has been done
for BICs such as Alliant and OASIS.
• SBA will work with members of the CMLC to increase use of “on ramps” and “off
ramps” in BIC and Government-wide solutions, where appropriate. These efforts will
include, to the extent feasible, an “open season” pilot, where a percentage of awards
are reserved for small businesses to on-ramp during the life of the vehicle. SBA will
provide recommendations for adjustments to small business strategic goals for each
category area to enhance the ability of BICs to contribute to the achievement of
Federal small business and socio-economic goals and promote job creation.
• The small business representatives to the CMLC shall apprise the CMLC no less than
annually on any opportunities for potential new Government-wide small business
vehicles, especially for HUBZone and women-owned small businesses. In addition,
category managers shall partner with SBA to identify opportunities to expand small
business offerings on BIC contracts.  For the full report, please click here: M-19-13_Category Management – Making Smarter Use of Common Contract Solutions and Practices (March 20, 2019)