Tuesday, December 15th, 2015
Preparation can be key to Successful Verification
If you are a veteran owned business pursuing federal contracts, it’s likely that you’ve heard complaints and horror stories about the VA Center for Verification and Evaluation (CVE) verification process, which must be completed to leverage your veteran (VOSB) or service disabled veteran owned small businesses (SDVOSB) status with the US Department of Veterans Affairs (VA) and Federal Aviation Administration (FAA). As a VA Certified Verification Assistance Program Counselor with the Washington Procurement Technical Assistance Center (PTAC), I’ve found that investing time on the front end to both understand how the VA will evaluate your business and to prepare all the documentation you will need prior to applying will simplify all phases of the process and significantly decrease the likelihood of receiving a denial. Avoiding a denial is always my goal, because firms denied CVE Verification must wait 6 months to reapply, which can be a lifetime in the world of federal contracting. When weighed against the prospect of being shut out of set aside and subcontracting opportunities for 6+ months, taking the time to adequately prepare to succeed seems a worthwhile trade-off.
I encourage my clients to follow these 7 steps to simplify the application process and decrease the risk of denial. You can also find additional information and tips in my four part webinar series on VA CVE Verification.
- Read the VA’s Initial Verification Application Guide
The Initial Verification Application Guide should be your dog-eared desktop Bible throughout the certification process. The guide contains an overview of the application process, an explanation of the core requirements for verification, and discussion of common reasons for denial.
- Review the regulations that govern Verification.
Regulations pertinent to VOSB and SDVOSB verification can be found in an easy to understand Q&A format in 38 CFR 74. Careful review of these provisions will help you understand how the VA will evaluate your business for ownership and control.
- Once you’ve reviewed 38 CFR 74, complete the Verification Assessment Tool.
The Verification Assessment Tool is a helpful resource that will walk you through a series of questions concerning control and ownership of your business. Based on your responses, it will generate a list of issues that could result in your application being denied, thus allowing you to determine if your firm meets the eligibility requirements and address problematic areas prior to applying.
- Based on any red flags raised by the Verification Assessment Tool (above), review the applicable Verification Assistance Briefs. These documents spell out how the regulations governing the Verification process are applied, covering a range of issues that can result in denial, including (among others):
• community property
• highest compensation
• working full-time in the business
• 51% direct, unconditional ownership, and transfer of ownership and control within two years of application.
- Review your System for Award Management (SAM) registration and SBA Dynamic Small Business Search (DSBS) profile and make sure that both are active and accurate. The following sections merit particularly close attention:o SAM:
– Assertions: You must have self-certified the business as a VOSB or SDVOSB.
– Representations and Certifications: The Veteran owner must be one of the individuals listed to negotiate pricing.
– Points of Contact: The Veteran owner must be listed as a point of contact.
– The Veteran owner(s) must be listed as a principal.
- Gather all of the documents required for your type of business.
It can be helpful to scan and save the required documents in a file with sub-folders that mirror the VA’s document numbers (i.e. a folder labeled1.1 License, 1.2 Resume, 2.1 Tax 1040, etc.). This will simplify the process when uploading each specific document type as required with your application. This file will also come in handy when you renew your verification at the two year mark and completely reapply at the four year mark.NOTE: The required document list is much more than a check list. In reviewing your application, CVE performs a detailed evaluation of the documents, which must clearly show that the VOSB or VOSB meets the requirements set out in 38 CFR 74.
- Contact a VA Certified Verification Assistance Program (VAP) Counselor for help.
This is perhaps one of your most important steps– your VAP counselor can review your application package, including supporting documentation, and help identify issues that may conflict with eligibility requirements outlined in 38 CFR 74. Your counselor can also explain the application process, including the relatively new pre-determination and pre-decision phases that provide the opportunity to make corrections or withdraw your application to avoid denial.
What is the VA CVE Certified Verification Assistance Program?
Procurement Technical Assistance Center (PTAC) counselors nationwide have received training and certification by the VA to guide businesses through the CVE’s verification process. What’s more, PTACs provide no-cost technical assistance to help businesses compete for federal, state, and local government contracts, so a PTAC counselor can help you leverage your VOSB or SDVOSB status once it has been verified, working with you to identify suitable contracting opportunities for your firm as well as the right strategies for you to pursue them.
For help with the CVE’s VOSB/SDVOSB Verification process, contact your local PTAC.