Comment on FR Doc # 2026-12561
Career Management InternationalOpposeBusiness
Summary: David Schiller, owner of CMI, opposes the proposed changes because they would remove protections and requirements that allow small businesses to compete for federal contracts. He argues that the removal of small-business considerations, market research requirements, and award announcements would significantly harm his firm's ability to grow and secure work.
My name is David Schiller, owner of CMI, Chief of Contracts. My firm provides Career/Employee Development Programs designed to help organizations and employees maximize their potential..
These changes would directly harm my business. The protections being removed are the reason a firm my size can compete at all.
Competing for task orders & big vehicles
Roughly 90% of our federal revenue comes through task orders, GSA Schedules, or other contract vehicles. Getting onto a vehicle took us 2 years and cost us over 10K, and if agencies no longer had to consider small businesses when placing orders, we would lose the majority of our business opportunities.
Growing past small
Our typical federal contract is around $400,000, and the work we are trying to grow into runs $800,000. If small-business consideration above $350,000 became optional, our path to growth would lose the momentum we have worked hard to establish.
Losing the people who open doors
A small-business specialist, OSDBU office, or agency market research led us to our first DoD contract worth about $90,000. Without required market research, buyers would likely bypass WOSBs and go with major contractors because small business wouldn't have to be considered.
Losing sight of who wins
We use award announcements to find prime contractors to work with as small business partners, and roughly 40% of our work comes from subcontracting or teaming. If the government stopped announcing its largest awards, we would lose our primary avenue to become subcontractors.
Sole-source opportunities going quiet
Public sole-source notices have let us step forward before an award is made. If sole-source intentions in our industry stopped being posted, we would never know when to make our case to the Federal Government.
Your certification losing its pull
Getting WOSB/EDWOSB certified took us four months and a lot of research and communications with the SBA, and it has opened up set-aside contracts that we would otherwise not have been privy to. If the program's name disappears from the publicizing rules, we expect fewer buyers to steer opportunities our way.
I support and incorporate by reference the comments filed in this docket by the U.S. Women's Chamber of Commerce — its principal comment (Comment ID FAR-2026-0005-0013) and its comment under 5 U.S.C. 610 (Comment ID FAR-2026-0005-0014).