YES!

The 8(a) STARS contracts were awarded under the provisions of Section 8(a) of the Small Business Act (15 U.S.C. 637(a)) and FAR part 19.8.  Based upon the statutory authority for directed (sole-source) 8(a) awards to be placed at or below the $3 million competition threshold, the contracting officer may waive and can easily document the competition waiver for orders at or below the competition threshold placed against the 8(a) STARS contracts.  However, the competition requirements of DFARS 216.505-70 are still applicable for orders above the competition threshold for 8(a) contracts unless the contracting officer waives this requirement on the basis of a written determination that -  (1) one of the exceptions described in FAR 16.505(b)(2)(i) through (iv) applies to the order; or (2) a statute expressly authorizes or requires that the purchase be made from a specified source.  The GSA Office of Governmentwide Policy has determined that directed orders at or below the competitive threshold placed against the 8(a) STARS contracts meet the qualification for exception to competition outlined in Section 803 of the 2002 National Defense Authorization Act.

YES, task orders under the $4 million competitive threshold may be awarded on a sole-source basis based on the provisions of Section 8(a) of the Small Business Act (15 U.S.C. 637(a)) and FAR 19.8.  Contract holders may utilize this unique provision based on self-marketing efforts or past performance.  All contract holders within a functional area must be given fair opportunity to compete when requirements exceed the $3 million competitive threshold in accordance with FAR Part 16. 

We recommend federal agencies regularly consider GWACs in their acquisition strategy for a variety of reasons such as limited protestability, pre-qualified pool of industry partners and acquiring the total solution under one vehicle.  In addition, 8(a) STARS has the unique benefit of sole source orders up to the $3 million competitive threshold – a benefit not found in any other contracting vehicle.  This saves the customer a great deal of time and money by not having to use the open-market provisions for 8(a) contracting outlined in FAR Part 19. 

There is no maximum order limit; however, there is a program ceiling of $15 billion.  The program ceiling is reduced as orders are placed against the contracts.

Read the ordering guide for helpful instructions on how to use 8(a) STARS II.

In general, you need to follow these steps:

1. Attend training

2. Request a delegation of procurement authority

3. Issue the task order Report contract actions Review past performance

4. Report contract actions Review past performance

5. Review past performance

Streamlined Technology Acquisition Resources for Services

Yes.  The 8(a) GWACs are very attractive to customers due to the unique procurement authority granted to 8(a) firms by statute.  In addition, the Small Business GWAC Center is a resource for customers and industry with regard to small business contracting rules and regulations.  Customers may conduct set-aside competitions using our GWACs as an alternative to lengthy and costly full and open competitions.  Acquisition Center training and support is also a plus. 

8(a) STARS has its own web page at www.gsa.gov/8astars2.  The Small Business GWAC Center also manages a toll-free number at (877) 327-8732.

You can download the ordering guide from www.gsa.gov/8astars2 or by clicking here

The Small Business GWAC Center is the GSA organization responsible for awarding and administering the contracts under its purview.  GSA receives annual approval as an Executive Agent from the Office of Management and Budget to manage governmentwide contracts for federal agency use.  The Center must maintain strict standards with regard to contract and task order oversight in order to continue its operations.  It accomplishes this through its communications and training held with customers and industry partners throughout the year.

Definition of GWAC (FAR 2.101):

“Governmentwide acquisition contract  (GWAC)” means a task-order or delivery-order contract for information technology established by one agency for Government wide use that is operated--

(1) By an executive agent designated by the Office of Management and Budget pursuant to Section 5112(e) of the Clinger-Cohen Act, 40 U.S.C. 1412(e); …”

GWACs have unique features and benefits that make them sought after alternatives when choosing an acquisition strategy for your next technology procurement.

• Fully competed, total information technology and network solutions contracts
•  Worldwide coverage
•  Technology refreshment
•  Non-protestable
•  Addition of skill levels at task order level
•  Program office support and oversight
•  Section 803 compliance

8(a) STARS II contracts are primarily for technology services.  Hardware, software and related supplies may be procured as part of an integrated solution. Leasing is prohibited under this GWAC. 

There is a contract access fee of 0.75% built into the contractors’ labor rates.  This fee covers operating costs associated with contract administration and training customers on the proper use of the contracts. 

Ordering offices have two methods of accessing the 8(a) STARS contracts.  A contracting officer may request a delegation of authority from the Small Business GWAC Center to use the contracts.   An ordering activity may also reach the 8(a) STARS contracts through the assisted services offered by the GSA Federal Technology Service. 

STARS is also available through GSA E-Buy

Yes.  Subcontractor teaming arrangements under 8(a) STARS are extremely flexible and are permissible the task order level.   Since this contract vehicle is set-aside, all subcontracting shall be shown on initial quotes.  In accordance with the Code of Federal Regulations (CFR), 13 CFR 125.6 a small business concern contracting for services has agreed that, the concern will perform at least 50 percent of the cost of the contract incurred for personnel with its own employees.  The location of the full text of this CFR can be found at www.sba.gov/library/cfrs/13cfr125.htmlThis is also stated in the contract in FAR Clause 52.219-14, Limitation on Subcontracting.  Contracting officers may request a statement from the contractor that shows the amount of work to be subcontracted on a task.  All contract holders are responsible for managing the balance of workload being performed under their contracts. 

The answer to this question is two-fold.  First, an 8(a) GWAC contract remains valid until the awardee is required to re-certify its small business size status.  A firm may have exited the 8(a) program during the contract period and still hold a valid 8(a) contract.  Secondly, the logical follow-on exception to fair opportunity applies when a contracting officer has originally competed an order under a multiple award contract, and then wants to issue an order to the same firm, for the same requirement, serving the same client, on a sole source basis (use of the follow on authority must be reasonable and documented.)  Orders under 8(a) STARS II that are issued on a sole source basis are done so under the statutory direct order authority for 8(a) procurements granted by the Small Business Act and therefore are not eligible for the logical follow on exception, but those that were competed are.  In addition, the logical follow-on exception may only be used once.