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    1. Is it written anywhere that the proposed team on SF330s cannot be revised after ranking but before award? 2. If not, should the Selection Board have to reevaluate the revised SF330 and re-rank all respondents since the revised team would not have the same qualifications as the original team, and thus may change the ranking of the firms?


    Answer

    Your question involves a number of FAR/DFARs sections, the Brooks Act, and recent legislation.  For a while A-E was a demonstration area and could be solicited unrestricted.  The demonstration program has been lifted, so A-E must now consider the full implementation of FAR 19.5 and .7.  Under 19, when the KO anticipates at least two qualified small business responders for any project, no matter the size, the proposed action should be considered for a set-aside.  Under DFARS 219 it only mentions A-E less than $300,000 must be set-aside for small business.

     

    Now consider the A-E industry.  How many small A-E firms can supply the quality and timeliness for any A-E project?  Any KO can probably estimate at least two small business A-E firms responding to every project and probably going through to be determined the most highly qualified proposer.

     

    FAR 19.7 states the KO, given good business acumen and not burdening businesses, may request the Subcontracting plan with the initial response. Though as you rightly point out, the subcontracting plan is a secondary consideration, with the keen A-E market we many times must go through all evaluation factor tiers to successfully delineate the most highly qualified A-E firm anyway.

     

    With the suspension of the demonstration program, KOs will need work more closely with their Small Business Advocates when soliciting and awarding A-E projects now.  If the A-E awardee is a small business, as you well know, the subcontracting plan requirement does not apply.

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