Last month I asked the questions, “What’s next?” and “Now what?” This is probably a question many of you ask after you get a lot of “good” information and you don’t quite know what to do first.
Well, I believe a decision needs to be made; your mind has to be made up. There was a saying by the United Negro College Fund, “A mind is a terrible thing to waste.” We have to methodically think about what’s next.
I would like to propose something for us to think about. Before I do, I would like to acknowledge the comments I received that HBCUs need to be more aggressive in areas addition to government contracts, and while I may agree, my concentrated area is government contracts. Why? Because, as I stated in my first blog, there is AT LEAST $190 million in the NASA agency specifically for HBCUs/MIs in government contracts. Why would we not pursue this huge opportunity?
So, I propose that we become more aggressive in the government regulation community to ensure a space is included for HBCUs. How do we expect to get fed if we do not have a seat at the table? A seat at the table would put us in a position to make decisions.
A seat at the table means we have both the influence and power to make decisions and affect change. Having said that, the Federal Acquisition Regulation (FAR) is the book, “the bible” that agencies follow to acquire goods and services. However, HBCUs are only mentioned in it briefly. In FAR Part 26 and when I say briefly I mean like three lines briefly.
The regulation states:
26.302 General policy.
It is the policy of the Government to promote participation of HBCUs and MIs in Federal procurement.
26.303 Data collection and reporting requirements.
Executive Order 12928 requires periodic reporting to the President on the progress of departments and agencies in complying with the laws and requirements mentioned in the Executive order.
What does that mean? Nothing! It does not require the agency to do anything specific for HBCUs. How do we expect to be part of a process that does not involve us? I propose that the FAR be modified to require the contractors to treat HBCUs as if they would a small business. I have heard rumblings that they do treat HBCUs like a small business, but how can they when it is not a regulated policy? The Small Business policy says:
19.202-4 Solicitation.
The contracting officer must encourage maximum response to solicitations by small business, veteran-owned small business, service-disabled veteran-owned small business, HUBZone small business, small disadvantaged business, and women-owned small business concerns by taking the following actions:
(a) Allow the maximum amount of time practicable for the submission of offers.
(b) Furnish specifications, plans, and drawings with solicitations, or furnish information as to where they may be obtained or examined.
(c) Provide to any small business concern, upon its request, a copy of bid sets and specifications with respect to any contract to be let, the name and telephone number of an agency contact to answer questions related to such prospective contract and adequate citations to each major Federal law or agency rule with which such business concern must comply in performing such contract other than laws or agency rules with which the small business must comply when doing business with other than the Government.
While I recognize that NASA has taken steps to establish an HBCU program, my experience and the lack of meeting their 1% mandated goal suggests that establishing a goal is not enough. I believe that if the FAR were more explicit in requiring such participation, it would serve to emphasize the critical importance of HBCUs and thus will give us “A seat at the table.”
Once we have a seat at the table, we must do the following things:
1. Prove value 2
2. Bring expertise, and
3. Uncover Insight.
How do we do this? I’ll tell you in next month’s blog.
