Comment on FR Doc # 2011-28827

I agree that keeping a company's CCR record up-to-date annually is no problem. But...What happens when a company wins a multi-year IDIQ contract as a small and then grows out of their NAICS code prior to the end of the contract? The annual re-cert process should not impact my ability to continue bidding task orders on an IDIQ I won as a small, even though I may now be classified as a large business prior to the end of the IDIQ's term. If the re-cert process will possibly be used to "graduate" companies on an annual basis out of a small business award, the customer will suffer from reduced competition, not to mention the pain of on-boarding each year if they choose to fill the vacated spots, and suffer a loss of continuity and momentum. Small businesses will suffer because we either won't bid in anticipation of graduating during the contract, which will stifle our growth, or we'll have to layoff potentially hundreds of workers a year after they're hired. If an IDIQ is longer than 5 years, let us re-cert for possible graduation at the 5 year mark, as is currently the standard. Don't force an annual graduation. That will undoubtedly cause more problems for small businesses and customers alike. Thank you for your time and consideration.