Revising the Veterans Certification – Top to Bottom

WomenVeteransAccording to the Small Business Administration (SBA) veterans own nearly 10% of all small businesses and those veteran-owned businesses generate more than $1 trillion dollars in revenue each year. In order to qualify for federal contracting preferences at the Veterans Administration (VA), these businesses have to certify as a veteran owned business. The Veterans Administration calls this program “Veterans First.” Government-wide contracting programs give preferences to service disabled veteran owned businesses (SDVOBs) which are required to go through the certification process at the VA.

The Veterans Administration is asking for comments on a new set of changes for the Veteran Owned Small Business program (VOSB). Among many other changes, the proposal would alter the definition of a veteran, a caregiver, the verification requirements for a VOSB, and requirements for joint ventures.

First, the definition of “veteran” in the program is now consistent with a recent update to the VA’s overall definition of veteran. This means owners who served in the National Guard or in the Reserves are still only eligible to be an owner of VOSB or SDVOSB if they received a service-connected disability. The single definition of “veteran” is intended to create consistency when applying to all programs within the VA.

Veteran owners would be required to oversee “daily business operations,” replacing the terms “daily business management” and “day to day operations” in an effort to simplify the application process. In addition, references to spouses and personal caretakers are removed, replaced by “permanent caretaker” to more clearly define a single role aiding the service-disabled owner. A letter outlining the service-disabled veteran’s disability and the need for the permanent caregiver must be included in order to qualify. The VOSB application process, which was required annually, would be expanded to last for two years if the proposed rule was adopted.

Last, language on VSOB joint ventures has been clarified, requiring at least one joint partner be a verified VOSB. Additionally, the same project and time restrictions that apply to other set-aside programs have been added. All these changes, and more, can be viewed and commented on here.

If you have an opinion on the VA certification, now is the time to submit them. Your comments will make a difference – agencies receive every submission and carefully review them.

1 thought on “Revising the Veterans Certification – Top to Bottom

  1. While I think it is essential that the Veteran’s Administration provide regulatory guidance to Veteran owned businesses, based upon the article above, it leaves many women veterans and relevant family members (many who are women) with nothing that acknowledges their contributions to and sacrifices for military service, not to mention the potential financial and emotional hardships they will endure as a result of the veteran’s military service.

    Without question, those veterans who have directly served for combat duty, where their lives were in constant peril should be allotted a significant preference in federal contract awards. If the veteran is disabled as a result of this service, the preference is doubly warranted.

    Nevertheless, there are two populations that I can think of where some preference consideration should be available. The first group that should be considered for inclusion into veteran contracting preferences are businesses that are started by “primary love ones” of deceased veterans killed on active duty or combat veterans who died because of disabilities as a result of combat. I would define “primary loved ones” as surviving spouses, children, parents, siblings or friends, who suffer a financial and emotional loss as a result of the death of the veteran. This group would include the person who would have continued to build a life both financially and emotionally should the veteran returned home. For example a deceased veteran may have had a fiancé, who would have been their partner (financially and emotionally) or primary caregiver if they had returned home, with whom had they returned home the soldier/veteran would have married and may have started a qualifying business. These “primary love ones” have given the ultimate sacrifice second only to the deceased veteran. For most parents, the thing most precious thing to them is their child. I just think the government in its contracting regulations should provide for that acknowledgment. To ascertain a “primary loved one”, perhaps the VA could look to next of kin and emergency contact information of the deceased soldier or veteran to provide the validation.

    For women veterans in the National Guard and those who were in the Reserves, the prohibition of their participation unless they have a service related disability is somewhat a slap in the face for service to our country. While I am not in anyway advocating the same level of preference as those who have endured a service related disability, to dismiss the contributions for those who have served in the National Guard and the Reserves seems indifferent or unappreciative of the service to our country.

    I recommend a priority system in the VA preference. Consider a hierarchy of preference:

    Service related disabled veterans and their permanent caretakers
    “Primary loved ones” of deceased veterans
    All other veterans including National Guard and Reservists

    Thank you for the opportunity to comment on this issue.


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