21 July 2013
Signing Up to be a Federal Government Contractor
Years ago, I signed my laboratory, Anderson Materials Evaluation, Inc., up as a federal contractor under the system the government was using at the time. I was submitting an SBIR proposal which turned out to be in competition with about 60 other small businesses for a research and development grant. About 6 weeks after these 60 small companies went to great expense to submit their proposals, the agency sent us a letter that said that because some other agency had requested a rather similar proposal a year earlier, they were not going to fund any grants under this request for proposals at all. There was, of course, no apology for the agency's lack of homework in requesting the proposals and no expression of sorrow for the blow to the many small companies who never even had a chance to get a return on their investment. Federal government bureaucrats simply are unable to imagine the harm they do. I decided that applying for SBIRs was just too risky for my business and went years without applying for any contracts.
Recently, I performed two analyses for a federal agency which so impressed it that it decided it wanted five more such analyses. These individual analyses were performed for three thousand dollars apiece and could be paid for with a credit card. Over the years since my last bad SBIR experience, any work I had done for the federal government was performed at its request for credit card payment without the formality of being a registered government contractor. As a result, my company did not need to be in the federal contractor system until this agency just requested that I respond to their RFQ for 5 more analyses on a contract.
So, I spent much of Thursday afternoon and evening and Friday afternoon setting my laboratory up in the new federal contractor system call SAM. This system is integrated with Dun and Bradstreet, so I had to update my listing there and figure out how to get SAM to update obsolete information it had from an old set of data from years ago from Dun and Bradstreet. Even before I could do that, I had to figure out how to get the system to authorize me to update the information it had imported from the old system in use years ago when I had put in a proposal for the ill-fated SBIR. Then I had to wait until Friday to get that authorization.
Among the remaining tasks was the required reading of 45 FAR and DFARS requirements placed upon federal contractors on a host of issues. One has to affirm that one is in compliance with each. To understand these federal requirements, one is often referred to various laws. In one case, one is told that the definition of an entity is to be found in a law and that it is different than the meaning the IRS gives to the same identifier in the Internal Revenue Code. Apparently, small business owners have an infinite amount of time that bureaucrats and Congressmen can assume is readily dedicated to the finer points of their games. No links are provided to the laws in question.
Once again, I am most impressed that the federal government has absolutely no sense of what expenses in time and effort it is appropriate to impose upon small businesses to do the work which the federal government is unable to do for itself. For the government to have any ability at all to pose as competent, it has to turn to contractors to do its work. Yet, when it does so, it does its darnedest to impose many of the inefficiencies and irrelevancies of the government bureaucracy on companies of the private sector. It has no concern whatsoever for the value of the small business management's time. None.
What the federal bureaucracy does care about is that it appears to have some concern for the issues of these FAR and DFARS. If some contractor does violate one of them, it wants to be able to slam the responsible parties into prison or to heavily fine them. Woe to the small business owner who rushes through these requirements without understanding them. Woe to the small business owner who uses the time he could be using to earn a living to thoroughly understand these requirements. This is a Catch-22 common to dealing with Big Government.
Many a small business simply cannot afford the assumed level of understanding and hence assumes a level of risk which the average citizen has no concern about, just as the bureaucrat and the Congress and the President have on concern. Big government does not like small businesses. It cannot comprehend a business which is less than very large. Small businesses with resources that actually have to be earned the old-fashioned way with hard work simply live in a different world from governments. Business owners are also a minority, so they count little at election time. Indeed, most politicians think it makes nothing but sense to treat small business owners as villains while courting the votes of the worker bees. Basically, government justifies its intrusiveness in everyone's life almost entirely upon the claim that business owners are villains and only Big Government can control them. So, who cares how much time government forces these villains to waste? It really is all very logical.
But, what would the private sector be without small businesses? It is odd that few voters ever give much thought to the function of government, either what is does or what it should do. It is even more odd that few voters think about the critical role of small businesses in the private sector that has to produce the wealth and perform the tasks so profligately squandered by Big Government.
Recently, I performed two analyses for a federal agency which so impressed it that it decided it wanted five more such analyses. These individual analyses were performed for three thousand dollars apiece and could be paid for with a credit card. Over the years since my last bad SBIR experience, any work I had done for the federal government was performed at its request for credit card payment without the formality of being a registered government contractor. As a result, my company did not need to be in the federal contractor system until this agency just requested that I respond to their RFQ for 5 more analyses on a contract.
So, I spent much of Thursday afternoon and evening and Friday afternoon setting my laboratory up in the new federal contractor system call SAM. This system is integrated with Dun and Bradstreet, so I had to update my listing there and figure out how to get SAM to update obsolete information it had from an old set of data from years ago from Dun and Bradstreet. Even before I could do that, I had to figure out how to get the system to authorize me to update the information it had imported from the old system in use years ago when I had put in a proposal for the ill-fated SBIR. Then I had to wait until Friday to get that authorization.
Among the remaining tasks was the required reading of 45 FAR and DFARS requirements placed upon federal contractors on a host of issues. One has to affirm that one is in compliance with each. To understand these federal requirements, one is often referred to various laws. In one case, one is told that the definition of an entity is to be found in a law and that it is different than the meaning the IRS gives to the same identifier in the Internal Revenue Code. Apparently, small business owners have an infinite amount of time that bureaucrats and Congressmen can assume is readily dedicated to the finer points of their games. No links are provided to the laws in question.
Once again, I am most impressed that the federal government has absolutely no sense of what expenses in time and effort it is appropriate to impose upon small businesses to do the work which the federal government is unable to do for itself. For the government to have any ability at all to pose as competent, it has to turn to contractors to do its work. Yet, when it does so, it does its darnedest to impose many of the inefficiencies and irrelevancies of the government bureaucracy on companies of the private sector. It has no concern whatsoever for the value of the small business management's time. None.
What the federal bureaucracy does care about is that it appears to have some concern for the issues of these FAR and DFARS. If some contractor does violate one of them, it wants to be able to slam the responsible parties into prison or to heavily fine them. Woe to the small business owner who rushes through these requirements without understanding them. Woe to the small business owner who uses the time he could be using to earn a living to thoroughly understand these requirements. This is a Catch-22 common to dealing with Big Government.
Many a small business simply cannot afford the assumed level of understanding and hence assumes a level of risk which the average citizen has no concern about, just as the bureaucrat and the Congress and the President have on concern. Big government does not like small businesses. It cannot comprehend a business which is less than very large. Small businesses with resources that actually have to be earned the old-fashioned way with hard work simply live in a different world from governments. Business owners are also a minority, so they count little at election time. Indeed, most politicians think it makes nothing but sense to treat small business owners as villains while courting the votes of the worker bees. Basically, government justifies its intrusiveness in everyone's life almost entirely upon the claim that business owners are villains and only Big Government can control them. So, who cares how much time government forces these villains to waste? It really is all very logical.
But, what would the private sector be without small businesses? It is odd that few voters ever give much thought to the function of government, either what is does or what it should do. It is even more odd that few voters think about the critical role of small businesses in the private sector that has to produce the wealth and perform the tasks so profligately squandered by Big Government.
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