GSA Polaris and its Impact on Small Business

As a key factor of the GSA’s stated acquisition strategy, the Government’s movement toward multi-agency contract vehicles is intended to streamline the procurement process while seeking to reduce inefficiency through the removal of redundant contract vehicles.  Some organizations competing for awards through existing contract vehicles, to include Alliant Small Business (Alliant-SB), may face a new challenge competing for one of the 310 awards distributed across four small business pools with well-defined award quotas ranging from 60-100 awardees.

Polaris is one of the most hotly anticipated government-wide acquisition (GWAC) vehicles among federal technology contractors, with the primary NAICS being 541512: Computer Systems and Design, small business size standard of $30M. The GWAC has an expected $15 Billion ceiling and will allow government agencies to obtain a range of services, including cloud platforms, cybersecurity, and software development technology through approximately 310 awarded – as stated by the GSA -small business contractors across small business, woman-owned small business, Hub-Zone, and Service Disabled Small Business (SDVOSB) competition pools. It should be specifically noted that GSA has made the decision to include 8(a) firms only as offerors within the broad “small business” pool, in which a total of 100 awards will be made by GSA.

It is worth noting that, according to USASpending.gov, 8(a) awards in 2021 comprised approximately 3% of all competed bids defined as small business. With a 3% share of small business awards, it is expected that 8(a) firms will experience a somewhat limited level of success on Polaris as they will now be competing with other small businesses, rather than only against other 8(a) firms. While it is entirely possible that, due to the specific pools for WOSB, SDVOSB, and Hub-Zone, that 8(a) share of wins will uptick from 3%, even if it 200 times greater than the 2021 award data indicates, 8(a)’s may only account for 6-9 awards across a landscape of 310 awardees.

While designed as a small business set-aside, potential offerors should keep in mind that the small business size standard is a five (5) year average of a firm’s gross revenue. As such, organizations that may be larger in annual revenue than the small business size standard will still be eligible to bid the program. 

Moreover, there has been a trend in recent procurements by various Federal acquisition and consolidated contracting authorities to mitigate the impact of subcontractor past performance.   RWCO notes the specific instance of contractor past performance and limitations to either subcontractor or Mentor past performance evaluation value within the procurement and subsequent protest cycle of the Department of Health and Human Services (DHHS), National Institutes of Health (NIH) NITAAC (NIH Information Technology Acquisition and Assessment Center) Chief Information Officer-Solutions and Partners 4 (CIO-SP4) Government-Wide Acquisition Contract (GWAC) under Government Accountability Office (GAO) File number(s) B-419956.18; B-419956.19; B-419956.24 [November 2021].