A Government Market Research Tutorial Presented by GovShop
The acquisition professional lives in a world of forms. There’s no way around it; nearly everything we do (or want to do) requires an approval form. From the DD Form 2579 in the Department of Defense to SF forms across the federal acquisition sphere, documentation is an essential cog in the procurement wheel. Yet forms don’t always have great instructions, leaving the contracting professional to track down the what, why and how for all those little boxes.
So let us make your job easier by breaking down each section of the DD 2579 and showing you how to get it done faster and more effectively using some key features in GovShop and elsewhere. Let’s get started!
What is a DD2579 and Why is it Used?
As a matter of policy, small and disadvantaged businesses should be afforded every opportunity to compete for and win government work, but how can an organization be sure their acquisition workforce is providing equitable opportunities? The Department of Defense uses the DD 2579 Form, also known as the Small Business Coordination Record. It serves as the check and balance to ensure the defense acquisition workforce includes small and disadvantaged businesses in their market research, and if possible, sets opportunities aside for such businesses wherever practicable.
The form is completed by the contracting professional and typically reviewed by the small business office (and sometimes the other way around). It’s part of the ever-growing list of documentation and forms levied on our profession, but at least this one is for a good cause! Let’s take a look at each section of this form and discuss how to complete it like a pro.
DD Form 2579 Instructions & PGI Guidance
The DD Form 2579 is prescribed in DFARS 219.201(10)(B) which describes the general policies around encouraging small business participation in Defense acquisition, the responsibility for which falls in the purview of small business technical advisors and specialists.
It is these personnel who will review and make recommendations on whether acquisitions should be set-aside for small business concerns (notwithstanding those that are totally set aside in accordance with FAR 19.502-2), and the DD Form 2579 is an important artifact in this review process. Per the PGI guidance, it is the contracting officer who is responsible for coordinating and completing this form (PGI instructions here), although it is not required when the acquisition uses a mandatory source at FAR 8.002 and 8.003.
Now that we’ve got the basic mechanics and guidance down, let’s take a look at each section of the Form and what to put in those little boxes.
Section 1 of the Small Business Coordination Record: Administrivia and a Commodity Code Goose Chase
The first section of this small business coordination record is primarily administrivia. Block one is a control number that the small business office can create to track forms they receive, and block two is the purchase request number. Block 3 is self-explanatory (estimated acquisition value, inclusive of options), as are the blocks for Procurement Instrument Identifier (PIID) at 4a-b and supplementary PIID (the PIID is for the contract or vehicle, and supplementary PIID is for the modification or amendment if applicable) at block 5.
Demographic information fills block 6 (the DODAAC is your Activity Address Code, and if you don’t know your Office Symbol find someone in your office who’s been there longer than you and ask them!). Then we get to block 7 where you get to start using your noggin. In block 7a, enter a description of what you’re buying. It’s a best practice here to not just scribble down as few words as possible; remember there’s a human being who’ll be receiving this form and they haven’t necessarily done the strategic market research you’ve done (you have done your strategic market research, right??). So try to be descriptive without being overly verbose considering they don’t necessarily have the same knowledge of the market sector as you.
Block 7b-d produces our first real hurdle, as you’re going to have to do some research to find the NAICs code plus it’s relevant size standard. There are tools for this but I’ll be honest; none of them are as easy as GovShop’s commodity code search, as you’ll see in this excerpt from our video tutorial on completing your DD 2579 form. It lets you search for common codes like NAICS by keyword, but unlike other databases, our search algorithm is smarter and finds better results to save you time.
Once you identify the right NAICS code, you can find the size standard determination using the table of size standards on the SBA website (it actually sends you to another link buried deep in the Electronic Code of Federal Regulations, which you can jump straight to here). It’s a LONG table, so use CTRL+F and enter your NAICS to make it easier on yourself. You’ll get a size standard determination either in annual receipts or number of employees, but never both. Enter this number in Block 7d and then pat yourself on the back! After entering the period of performance in block 8 and the reason you’re sending this form up in block 9 (or if something changes, why you’re sending it back or withdrawing it), and you’re ready for the next section.
Section 2 of the DD 2579: The Fun(ish) Part!
Your reward for completing the preceding sections is to make a recommendation based on your business judgement! You’ll get to do that and more, but it does start with a range of check boxes in block 10 where, based on the market research you’ve done (you have done market research, right??) or are about to do, you can recommend to the small business official whether and how this upcoming solicitation will be set aside for the small business community.
So how do you know which boxes to check? By using the Rule of 2 for small business set asides, which essentially dictates that if there are two or more qualified small businesses capable of doing the work, and you can get a fair and reasonable price for the items from them, you should set it aside for the small business socioeconomic category. Of course, there are a lot of socioeconomic categories to choose from, and it can be tough to discern them all from something like the SBA’s Dynamic Small Business Search. We have all used this tool, but we weren’t satisfied with it so we created GovShop filters to make searching for, and finding, small and socioeconomically disadvantaged businesses easier. In the video clip below I demonstrate exactly how well-suited GovShop is for government market research.
Using GovShop, you can easily see how many of a particular socioeconomic category are present within a market. You’ll want to make sure your research parameters are on point (we’ve got a case study on that here, and a tool for that as well), but once you do, it’s fairly easy to see the density and distribution of socioeconomic concerns in your market research results using the GovShop Summary Report.
This is especially useful as you get along to block 11a, which asks you to attach your acquisition plan (if required), any requisite justifications and approvals, and “findings that demonstrate efforts to locate qualified small business sources.” Enter the Summary Report, a perfect piece of evidence that can save you a lot of extra paperwork when you’re inevitably asked to show your work.
- Start by creating a list
- Use our GSAT keyword research to transition from strategic market research to tactical market research
- Add relevant suppliers to your list
- Go to List and then create summary report
This is the most labor intensive part of completing the DD 2579 form, but using GovShop and the Summary Report will make your life easier while also improving your market research results. Once you’re done, it’s just a few more boxes to complete this section. Block 11b asks you to check whether or not a synopsis is required (it usually is, but check the FAR guidance for more info if you aren’t sure), and block 11c is about whether small business progress payments will be allowed (a good consideration, especially if you’re awarding to a socioeconomic concern; here’s the DFARs guidance at 232.501-1(a)).
Section 3: Consolidation, Bundling & Subcontracting Plans
Block 12 deals with a concept that always seems to give acquisition professionals trouble: consolidating or bundling your requirement. This is a more advanced topic than we have space for here, but generally speaking it’s a preventative measure against combining multiple contract requirements into one larger contract for the purposes of avoiding a set-aside. Read more about bundling at FAR 7.107.
Subcontracting plans are the topic of block 13, and whether or not one is required depends on your recommendations in block 10. Generally speaking, if you aren’t recommending a set-aside, you’ll want to maximize small business participation through subcontracting. As per statutory requirements at FAR Section 19.702, any contractor that receives a contract over the simplified acquisition threshold must agree that small businesses “will have the maximum practicable opportunity to participate in contract performance consistent with its efficient performance.” To go deeper into subcontracting is outside the scope of this blog, but know that you’ll have to demonstrate in your DD2579 the actions you’ll take to honor the statute, whether it’s through an evaluation preference to prime’s who subcontract to small businesses or stating detailed objectives for a prime’s subcontracting plan.
Section 4: The Acquisition History
In this section, you’ll identify the acquisition history, specifically whether the prior contract (if there is one) was set-aside for small businesses. As a general rule of thumb, once a requirement has been set aside, it tends to stay in the set-aside program for the duration of its existence. This is not a hard and fast rule, but it is difficult to wrest something that small businesses have been delivering and then give it to medium and large businesses. Exceptions can be made of course, such as performance issues or changing market dynamics, but the intent of block 14 is to provide the small business agent with the acquisition history so they may determine that whatever future decisions are made are appropriate with the decisions made in the past.
If this is not a new requirement, you’ll want to get your hands on the prior contract (and ideally, the DD2579 plan associated with it) to assist you with completing boxes a through c. Most times, you’ll mark item (1) and then one of items (2) through (10) based on the set-aside decision that was made, if there was one, and then identify whether it was previously consolidated or bundled. Box 14c requires a bit of narrative as you describe any relevant details of the previous awards. If you aren’t going to be setting aside this contract for a requirement that is not new, you’ll probably need to focus your attention here on why the small business community is not in position to handle this.
In our experience, this section accounts for most of the back and forth between a small business officer and the contracting professional, so if you want to save yourself the trouble, spend extra time on the details of previous awards, or better yet schedule a meeting with your approving officials to get a better understanding of their expectations for the acquisition history.
Section 5: Routing your DD2579 for Approval
Congratulations, your thought work here is done! Now it’s time to route your small business coordination record for approval. As a matter of style, it’s a nice touch to type in the names and email addresses of the approving officials if you know them; if not, they can always write these in manually or, if your office uses any e-sign technologies, they’ll be able to apply everything digitally.
Routing is a testy time. You’ve just worked hard to complete a form and make a recommendation, and so it’s likely that you feel a degree of ownership over and pride in the work you’ve done. It is natural to feel defensive emotions if the form comes back with a request for additional detail or questions about what you’ve proposed, but it is important to resist taking this personally. Every official in this signature chain is responsible for the form as well, or else they wouldn’t be required to sign it.
Exercise patience and professionalism when dealing with send-backs, and if you have questions or need clarification on the requests, it’s always better to pick up the phone than to engage in a back and forth email exchange. People are people, and always respond better to a more personal touch.
Once you’ve completed the approvals, you’ll be done with your DD 2579 form and ready to get on with your acquisition. Hopefully the time you’ll have saved using the tips in this tutorial will give you more time to conduct tactical market research on suppliers of interest so you can write a better requirement for your procurement customer. Good luck and happy routing!