FAR 5.202(a)(4) states that as an exception to synopsizing, a "contract action is expressly authorized or required by a statute to be made through another Government agency, including acquisitions from the Small Business Administration (SBA) using the authority of section 8(a) of the Small Business Act..." However, FAR 19.804(2)(c) states "All requirements for 8(a) competition... including construction, must be synopsized through the GPE." Does an agency have to synopsize a competitive 8(a) requirement before posting the solicitation? The 8(a) offer has already been made to SBA and accepted.
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Yes, an agency does have to synopsize a competitive 8(a) requirement before posting the solicitation. If it makes you feel better, I think FAR 5
should be organized differently to make this information clearer to the reader. Please look at FAR 5.205(f).
This part discusses "special situations" and provides the consistency with the wording at FAR 19.804(2)
, (c). FAR 5.205 (f)
says f) Section 8(a) competitive acquisition. When a national buy requirement is being considered for competitive acquisition limited to eligible 8(a) concerns under Subpart 19.8, the contracting officer must transmit a synopsis of the proposed contract action to the GPE. The synopsis may be transmitted to the GPE concurrent with submission of the agency offering (see 19.804-2) to the Small Business Administration (SBA). The synopsis should also include information --
(1) Advising that the acquisition is being offered for competition limited to eligible 8(a) concerns;
(2) Specifying the North American Industry Classification System (NAICS) code;
(3) Advising that eligibility to participate may be restricted to firms in either the developmental stage or the developmental and transitional stages; and