Throughout the rule's specific changes, the assumption is made that each firm operates under a single NAICS code and associated size standard. That is often not the case. The final rule and specific subpart changes need to address the misrepresentation of size when a firm claims small business status under one NAICS code on a procurement for work being procured under a different (more restrictive) NAICS code. This also includes listings on procurement databases.
Firms may perform work under multiple NAICS codes with significantly different size standards. They should not be allowed to carry their size from a more lenient standard to work identified as being covered by a more strict standard (e.g. Environmental Services – 500 FTEs versus Environmental Engineering - $4.5 million).
Comment on FR Doc # 2011-25656
This is comment on Proposed Rule
Small Business Size and Status Integrity
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