Comment on AM78-Final Rule-Unknown Submitter

Document ID: VA-2008-VACO-0019-0007
Document Type: Public Submission
Agency: Department Of Veterans Affairs
Received Date: February 17 2010, at 12:00 AM Eastern Standard Time
Date Posted: February 22 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: February 8 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: March 10 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80aa676b
View Document:  View as format xml

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§ 74.1 What definitions are important for VetBiz Vendor Information Pages (VIP) Verification Program? Full-time means working at the business during the normal working hours, which equate to Monday through Friday, approximately 9 a.m. to 5 p.m. COMMENT: This definition does not take into account small businesses where the Service Disabled Veteran Owner who is responsible for the Day to Day Management and Operations works other shifts such as in the Janitorial, Security Guard, and Building Maintenance Businesses. Recommend removing 9AM to 5 PM and rewording to “Full-time means working no less than 40 hours per week involved in the Day to Day management and/or Operations of the Business.” Principal place of business means the business location where the individuals who manage the concern’s day-to-day operations spend most working hours and where top management’s current business records are kept. If the office from which management is directed and where the current business records are kept are in different locations, CVE will determine the principal place of business for program purposes. COMMENT: This definition does not take into consideration that managing a Service Disabled Veteran Owned Small Business is not always in an office or one single location. In the commercial business world we often have many work sites/locations often many miles apart and Management must get out and visit these sites and Clients an example of these are Janitorial, Security Guard, and Building Maintenance Businesses. Recommend adding the following “CVE recognizes that the Service Disabled Veteran Small Business uses modern technology such as computers, the Internet, Cell Phones and Blackberry to leverage their time and location to maintain control of their business and therefore are not always tied to a desk.”

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