A Guide for Women in the Security Industry
In 2016, the U.S. Department of Defense, the General Service Administration (GSA) and NASA adopted a final ruling amending the Federal Acquisition Regulation (FAR) to implement regulatory changes made by the U.S. Small Business Administration (SBA) providing authority to award set-asides and sole source contracts to economically disadvantaged women-owned small businesses (EDWOSB) per FAR 52.219-29 and women-owned small businesses (WOSB) per FAR 52.219-30. The rule provides a much-needed resource to federal agencies to meet the mandated 5 percent of all prime and subcontract contracts for small women-owned businesses.
The rule provides that EDWOSBs and WOSBs may receive set-asides and sole source awards in industries designated by the SBA and North American Industry Classification System (NAICS) codes as “underrepresented” by women. Under the rule, an agency may make a sole source award in an appropriate industry where:
- the contracting officer does not have a reasonable expectation that two or more EDWOSBs/WOSBs will submit offers,
- the anticipated award price (including options) will not exceed $6.5 million for manufacturing contracts and $4 million for other contracts,
- the EDWOSB/WOSB is responsible and
- in the estimation of the contracting officer, the award can be made at a fair and reasonable price.
The rule allows the SBA or the contracting officer to protest the prospective awardee’s EDWOSB or WOSB status. A competitor, however, cannot file a formal EDWOSB or WOSB status protests in regards to a sole source award.
For women-owned businesses in the security industry, this is good news. Qualifying NAICS Codes for WOSB include, for example: 561621 – security system services (except locksmiths); 561622 – locksmiths; 561611 – investigation services; 561612 – scurity guards and patrol services; 561990 – support services; 541990 – all other professional, scientific and technical services; 541690 – other scientific and technical consulting services; 541330 – engineering; 334512 – automatic environmental controls (physical access control); 334390 – other communication equipment manufacturing (video management systems); and 541511, 541512, 541513 and 541519 – computer programming, design, management and other related services. These are just some of the categories related to the security industry that may apply to your business as you register your company for doing business with the federal government at the System for Award Management (SAM), a mandatory action.
If you are a woman entrepreneur considering starting a business or an established women-owned small business looking to do business with the government, the best starting point is the SBA’s guide.
SBA’s Office of Women’s Business Ownership (OWBO) provides a wealth of information and assistance. OWBO was established to help women business owners with various programs coordinated by district SBA offices. Every state has an office, and some of the larger states have regional offices. OWBO oversees the Women Business Center, which has a nationwide network of over 100 educational centers specifically designated to help women entrepreneurs. Learn how to connect with your local SBA district and get resources in your area. The center offers training and counseling in several languages with a strong focus to assist in overcoming economic and social disadvantages. Other resources include local assistance with SBA loan programs and a lender match tool.
More established women-owned businesses may want to consider doing business with the federal government. The SBA has established a women-owned small business federal contracting program. Understanding and complying with eligibility requirements to be considered as a WOSB or EDWOSB under this program is essential to success and assuring compliance for potential orders. Without this step, your company could be considered ineligible for a woman-owned set-aside or sole source at award. As previously noted, there is a 5% contracting goal for women. Certain government contracts have limited competition and restrictions to specifically benefit EDWOSB and WOSB.
Per Title 13 Part 127 Subpart B of the Code of Federal Regulations, a company must meet the following requirements to be considered a WOSB:
- Be a small business
- Be 51% owned and controlled by women who are U.S. citizens
- Have women manage the day-to-day operations and make long-term decisions
To be considered as an EDWOSB, a company must:
- Meet all the requirements of WOSB
- Be owned and controlled by one or more women each with a personal net worth less than $750,000
- Be owned and controlled by one or more women each with $350,000 or less adjusted gross income averaged over the last three years
- Be owned or controlled by one or more women each with $6,000,000 or less in personal assets
WOSBs must certify at certify.sba.gov.
A company may self-certify or use a third-party certifier. You must first register your company with SAM at sam.gov. Be prepared to provide specific company and staff information and attest to various certifications and representations for your company. Then you must upload additional required documentation into the WOSB repository; this checklist can help you prepare for the SBA WOSB self-certification. The checklist will detail the appropriate documentation needed to be submitted for certification of your company’s eligibility, whether a WOSB or an EDWOSB, including financial information and, if applying for EDWOSB, a narrative of very specific details on incidents of discrimination socially and economically as a woman owned business.
There are four organizations approved by the SBA to provide third-party WOSB certifications:
- EL Paso Hispanic Chamber of Commerce
- National Women Business Owners Corporation
- U.S. Women’s Chamber of Commerce
- Women Business Enterprise National Council
Certification from third-party organizations, although not required, can be very beneficial to verifying your WOSB status. Both government agencies and other prime contractors or Fortune 500 companies looking to certify their partners may give strong consideration with WOSB certifications are presented. SBA does not send certification letters.
Registration of your company in SAM, consulting with SBA, taking advantage of the unique eligibility and special concessions for WOSB and EDWOSB may help your women-owned security business obtain new customers. Seek opportunities with prime contractors required to set aside business for women-owned small businesses. The WOSB program also applies to the GSA Multiple Award Schedule contract, which offers a streamlined contracting vehicle for federal, state and local government, universities and other public institutions for purchasing security products and services under GSA Schedule Contract 84. This program contains the products and services deemed eligible per the NAICS codes for WOSB set-asides and sole source awards, as previously noted. A third-party certification as a WOSB may be a great marketing advantage.
Ladies, let’s take advantage of the resources provided to help us succeed in business through the SBA and other advocacies for women. Consider these unique opportunities to expand our businesses as available to us for selling products and services to the federal government under a program offered to assist WOSBs with a focus applied to our industry. Be aware that, in addition to the SBA WOSB program and federal set-asides, the security industry is encouraging growth of diversity. For further discussion, additional support and encouragement is offered through groups such as the Security Industry Association’s Women in Security Forum.