WHAT HAPPENS AT: SSC Small Business Office

  • Published
  • By Lia Sodders, SSC Public Affairs
Imagine for a moment that you’re a busy contracting officer at Space Systems Command, the acquisitions arm of the U.S. Space Force. You receive an acquisitions package that takes two existing contracts and combines them into one. One of the contracts is a $40 million small business set-aside and the other is a $30 million Service-Disabled Veteran-Owned Small Business (SDVOSB) set-aside. The new combined contract has a value of $90 million and will be full and open since there were no qualified small businesses that could perform the majority of the required work.

Do you push this forward as is? Or do you contact SSC’s Small Business Office because you know this scenario will raise several alarms?

Aaron Parra, director of SSC’s Small Business Office, says he hopes it’s the latter. The Small Business Office exists to help SSC steer clear of breaking any federal contracting regulations, and also to make sure SSC harnesses the very best and most innovative technology that our Nation’s small businesses have to offer.

“Small businesses really are the building blocks of our space community,” Parra said. “There are a lot of small businesses out there, and that’s part of what this office was created for - so we are not overlooking the solutions that come from small businesses. These are vendors that harness a vast array of knowledge, innovation, creative solutions and, in many cases, better prices than their large business counterparts.”

The fictional case above is an example of contract bundling and could lead to several repercussions, including Congressional inquiry. While cost factors can be a reason for potential contracts to not be set aside for small businesses, the bundled contract would have cost the government – and by extension – U.S. taxpayers – more money than the original two separate contracts; a clear violation of federal law.

“If we provide feedback for a set-aside because the requirement meets the ‘rule of two;’ meaning that two, qualified, capable, and responsive small businesses have been identified who can do the work, and then the set-aside doesn’t happen, the result is likely a Congressional inquiry and it’s going to be very difficult to justify that decision," Parra explained. “If the Small Business Office advises to do a set-aside, it’s to make sure that we pass this level of review because concerns can elevate very quickly.”

SSC manages multi-million-dollar contracts for capabilities and systems ranging from space vehicles to satellite payloads and ground systems, and a large percentage of contracts involve large contractors known as “Primes,” Parra said. Last year, however, SSC set records in funding awarded to small businesses in various categories.

“When we talk about set-asides, the vast majority at SSC are just plain,” Parra said. “Most of our awards to small businesses are total small business set-asides, as opposed to a set-aside for companies with a socio-economic component, such as service-disabled veteran-owned. We awarded over $1.2B to small businesses in FY25 and most of those dollars were a result of set-asides.”

That doesn’t mean the Small Business office will always push for a set-aside. Parra said, “A lot of folks reach out to us with some hesitation thinking we’re going to tell them they can’t do something they want to do. However, our team takes all factors into consideration when evaluating acquisition strategies in order to ensure program requirements are met.”

If a small business set-aside is not appropriate for the action, the team will suggest and support an alternative strategy. “The last thing we want to do is set a small business vendor up for failure,” Parra explained.

“Very few of SSC’s contracts are suitable for small businesses, but in those instances, we help on crafting language that’s going to pass additional scrutiny from our (external) stakeholders,” Parra said, which include the U.S. Small Business Administration, the Dept of the Air Force Office of Small Business Programs, as well as Congress.

The Small Business Act was created in 1953 by then-President Dwight D. Eisenhower, with the goal of maintaining the country’s full productive capacity and “to ensure that a fair proportion of the total purchases and contracts or subcontracts for property and services for the government be placed with small business enterprises.” The act has been revised over time, including adding government-wide targets for small business participation, such as the current no less than 5 percent of the total value of all prime contract and subcontract awards for each fiscal year.

How are small businesses defined? Every SSC solicitation is assigned a North American Industry Classification System (NAICS) code that has a corresponding size standard. Some are employee-based, others are revenue-based. The business must be for-profit, must have a place of business in the United States, and contribute to the U.S. economy.

Beyond that, there are other, specific categories including: Small Disadvantaged Businesses (SDB) that are owned and controlled by one or more socially or economically disadvantaged individuals; Woman-Owned Small Business (WOSB), especially STEM, engineering and construction companies where women are traditionally under-represented; service-disabled veteran-owned small businesses (SDVOSB); and historically underutilized business zone (HUBZone), for companies located in areas that fall below certain economic markers.

With regards to the HUBZone program, an additional component is that at least 35 percent of its employees must live in a HUBZone, although not necessarily the same one where the business is located. “That makes this particular program a bit of a challenge because it’s somewhat of a moving target,” Parra explained. “If the HUBZone becomes successful, it might no longer be a HUBZone, which makes this category historically a bit difficult for the government to meet.”

At SSC, the Small Business Office reviews all acquisition contracts greater than $15,000 to determine small business participation. That included review of more than 450 contracts in fiscal year 2024.

“We review the market research, sources-sought responses, market trends, vendor capabilities, and any documentation that we feel is necessary to make a decision on the acquisition strategy,” Parra said. “We advise acquisition teams, including program managers, on crafting solicitations, specifically Section L (Instructions to Offerors) which is proposal format, content, and submission as well as Section M (Evaluation Factors), the criteria and methodology for selection.”  

The office assists with Small Business Participation Commitment Documents, subcontracting plans, and reviewing acquisition strategy panels to make sure small businesses are receiving a fair proportion of subcontracting dollars.

“Federal contracting laws can be complicated,” Parra said. “And SSC’s Small Business Office is here to help.”

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