The Small Business Strategy the Army Recommended to Other Programs
How a $4.1B communications acquisition was restructured before anyone submitted a proposal — and what that means for companies seeking to enter the defense market.
The situation
In 2011, I served as the Contracting Officer responsible for all pre-award activities for the Communications and Transmissions Systems acquisition — a five-year, multiple-award IDIQ with a $4.1 billion ceiling that covered the full life cycle of Army communications systems: satellite telecommunications, deployable terminals, and the sustainment supporting them.
An acquisition of that size does not simply get advertised. Before any company sees a solicitation, a small group within the government decides how the work will be packaged, which contract vehicle will carry it, how many awards there will be, which NAICS code applies, and whether small businesses have a realistic path to compete. They document, staff, and approve those decisions. By the time an RFP appears on SAM.gov, they are effectively final.
The problem
As the acquisition strategy took shape, I concluded that the small-business approach did not hold up.
Large consolidated requirements create a structural problem. When work previously executed across multiple contracts is rolled into a single vehicle, the resulting scope's scale and breadth can put it out of reach for firms that were successfully performing pieces of it. The government must examine this — a consolidation of contract requirements triggers a Determination and Findings that must assess the impact on small business participation and justify the approach.
The initial strategy would have satisfied the paperwork requirements. My assessment was that it would not have produced a genuinely competitive path for small business, and that a strategy that cannot withstand scrutiny at the Department of the Army level will cost the program schedule later, whether through a rejected review, a protest, or a thin competitive field.
Raising that internally meant telling a program office that the plan they were working on needed to change.
What we did
The fix was not a document edit. It required rebuilding the underlying approach with the offices, each of which controlled a piece of it:
Army Sustainment Command Small Business Office and the Small Business Administration Procurement Center Representative — on what constituted a defensible and genuinely accessible small business pathway, not a nominal one
PM DCATS, the program office — on how to preserve the mission requirement and the acquisition schedule while changing the structure
ASC Legal — on the sufficiency of the consolidation Determination and Findings
ACC-RI management and Headquarters ACC — on staffing the revised strategy through Department of the Army and DoD review
I rewrote the acquisition strategy and the consolidation Determination and Findings, then developed the Source Selection Plan and Sections L and M — the instructions to offerors and the evaluation criteria the board would apply.
Then I briefed it to the Director of the Department of the Army Office of Small Business Programs.
The outcome
The strategy was approved.
More usefully, the Office of Small Business Programs did not simply concur. They advocated the approach and recommended it to other Army programs pursuing similar multiple-award vehicles. A structure built to solve one program's problem became a reference model elsewhere.
The acquisition advanced to source selection, which I later chaired — a Source Selection Evaluation Board of 27 evaluators working across three locations and applying the criteria I had drafted two years earlier.
A second acquisition followed the same pattern. For Program Management Support Services-3 — a $461M multiple-award IDIQ with a small-business reserve — I developed the strategy, drafted a detailed memorandum defending a change to the NAICS code, and briefed the AOSBP Director. She concurred with only minor changes.
Why this matters if you are trying to enter this market
Most companies encounter a federal acquisition when the solicitation is released. By then, the questions that determine whether you can realistically win have already been answered by someone else:
Was the work consolidated, and was that consolidation justified? Scope breadth is often the single largest barrier to a smaller or newer entrant, and it is a decision, not a fact.
What NAICS code applies? It sets the size standard, which sets who is small. It is arguable, and it gets argued.
Is there a small business reserve or set-aside, and is it structured to be reachable? A pathway that exists on paper and a pathway a real company can execute are not the same thing.
What do Sections L and M actually require? The evaluation criteria are written months before you see them, and they reflect what the government decided to care about.
None of this is fixed. All of it is authored — by contracting officers, program managers, small business specialists, and lawyers, working through market research, industry engagement, and acquisition planning, typically twelve to twenty-four months before an RFP.
That is the window. Companies that engage during it — responding substantively to sources sought notices and RFIs, attending industry days with something to say, making their capability legible while the structure is still being decided — are competing on terms that account for them. Companies that arrive at RFP release are competing on terms someone else set.
I spent twenty-two years on the government side of that process, including writing those documents, chairing the boards that applied them, and briefing them for approval. I now help companies read acquisitions the way the people who built them do.
Dean C. Brabant is President, Federal Services at Illumina Consulting LLC. He served as Chief, Industrial Base Division, Munitions and Industrial Base Directorate at Army Contracting Command – Rock Island, and previously as Branch Chief and Contracting Officer with unlimited procurement authority. He holds an MBA from St. Ambrose University and a Master of Strategic Studies from the U.S. Army War College, and is a Harvard Senior Executive Fellow.
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