![]() The final rule also imposes several requirements designed to ensure that there is no affiliation or control between mentor and protege. Imposing a Half Small limit will almost certainly further reduce the number of firms participating in the program. According to the final rule, there are only 85 proteges currently participating in the DoD Mentor-Protege Program. I don’t like restricting proteges in this manner. The final rule adds a new size restriction: it says that an eligible protege must be “ess than half the Small Business Administration (SBA) size standard for its primary North American Industry Classification System (NAICS) code.” I guess if the SBA’s program is the All Small Mentor-Protege Program, the DoD’s is now the “Half Small.” Perhaps in 2020, Congress will honor the program’s 30th birthday by finally removing the “pilot” label. Even though it was first established in 1990, the DoD Mentor-Protege Program remains a “pilot” program and requires occasional renewal. The final rule also extends the program through September 30, 2021, which is of course a good thing. for at least the 1-year period preceding the solicitation of sources by DoD for the procurement or transaction” and (5) an entity that currently provides goods or services in the private sector that are critical to enhancing the capabilities of the defense supplier base and fulfilling key DoD needs.Įxpanding the universe of potential DoD proteges is a good step–although it’s undermined by a rather nonsensical size limit I’ll discuss momentarily. ![]() The final rule adds (1) an entity controlled and owned by an Indian tribe (2) an entity controlled by a Native Hawaiian organization (3) an entity owned and controlled by socially and economically disadvantaged individuals (which sounds a lot like an SDB to me) (4) a so-called “non-traditional defense contractor,” which is defined as “an entity that is not currently performing and has not performed any contract or subcontract for DoD that is subject to full coverage under the cost accounting standards. The old rule limited the universe of proteges to small disadvantaged businesses (including 8(a)s), SDVOSBs, HUBZones, WOSBs, and entities employing the severely disabled. ![]() Unlike the SBA’s mentor-protege program, the DoD mentor-protege program isn’t open to “ordinary” small businesses–instead, an eligible protege must fit within a permitted category. ![]() Here is my take on the good, the bad, and the ugly from the final rule. The rule took effect on March 23, 2018.Īmong the major changes, DoD has both expanded and contracted the universe of potential proteges–and has included a mandatory certification that seems to completely misunderstand the SBA’s joint venture rules and processes. The DoD has issued a final rule making major changes in the DoD “Pilot” Mentor-Protege Program. ![]()
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