Comment on FR Doc # 2026-12561

Blake Consulting LLCOpposeBusiness
Summary: Maureen Blake, owner of Blake Consulting LLC, opposes the proposed changes to SBA categories of small business awards. She argues that these changes will disadvantage small businesses by removing the 15-day head start on smaller purchases, reducing the government's access to unique small-business talent, and making it harder for small firms to compete against larger entities.
My name is Maureen Blake, owner of Blake Consulting LLC. My firm is located in Purcellville, VA and provides contract management and professional services support to both the commercial sector and federal government. While I support streamlining the FAR to remove obstacles to efficiency and reduce fraud, the changes to SBA categories of small business awards proposed will do the opposite. The reason for the SBA Set aside programs was to ensure there are a plurality of solutions and talent presented to the government which would not otherwise be presented. Set aside awards directly strengthen our local economies, support "Buy American" most directly, and with each award having a 100% solely positive impact our U.S. economy which cannot be said for large business awards. Finding opportunities with time to respond will be exceptionally difficult and reduce possibilities of success. Blake Consulting LLC discovers federal opportunities via SAM.Gov. It takes two to three weeks to prepare a bid or quote. If the guaranteed 15-day head start disappeared on smaller purchases, we would be unable to effectively compete with larger firms because I do not have dedicated business development staff or proposal writers. The same personnel supporting creation of RFPs are those providing services to existing clients. I do however have access to unique talent that the government will not otherwise be introduced to at this time, despite their past stellar performance on prior government projects. Devaluation of SBA Certifications Impacts Excellence SBA Small businesses which have received certifications such that they are eligible for dedicated SBA set aside programs have been vetted through a stringent process which itself distinguishes them as the best of the best. When certified by a third-party organization as a small business in 8A, hub-zone, women or as disabled and veteran owned, small businesses participating in specified categorical certification programs demonstrate they are exceptional at meeting stringent guidelines for operations and record keeping, tax compliance and financial soundness. To disregard this exceptional distinction is to reduce the access of the federal government to the best of the best of the small businesses. Those who would be capable of competing meaningfully would be in reality those who are not really small but act as de-facto agents for large companies intent on retaining businesses by the shell game of creating subsidiaries in fact, even if not in name. If the government intends to prevent fraud, gutting the SBA small categories is not the way to do so as it would leave less oversight to know there is integrity of the 'Small" actually being what it purports to be. Once all small businesses are lumped into one bucket, there will be less way to distinguish between them. The ones who even have access to calls for work will be dramatically reduced as many small businesses will never be able to compete to move as quickly and as efficiently as those "smalls" That really have the backing of a large firm's office staff, resources and personnel behind every proposal they send in. In the gov con support space it is no secret the most profitable firms are the ones sold. Period. It is hard enough to make profit as a small business, and even harder when the one's left standing are owned by large equity partners, along with their resources, small in name only. Losing the people who open doors A small-business specialist, OSDBU office, or agency market research led us to knowledge to be able to understand the process to bid to win work. Without required market research, buyers would likely not get connected to many talented individuals who are aligned with small businesses because the small firms do not have the resources to respond timely to calls for proposals. To eliminate market research to discover capabilities in the commercial sector of small businesses will leave only those who have existing relationships at the table of consideration by the government. You will cut off some of the most innovative and capable people that offer unique solutions. Less overhead by smalls businesses means lower costs and greater efficiency of process and performance in many cases. This is hardly optimal for our government seeking to streamline and improve efficiency. 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).

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