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Small Business Concerns Policy

Effective Date: May 2007 

Policy Statement

It is the policy of Columbia University that Small, Small Disadvantaged, HUBZone, Women-Owned Small, Veteran and Service-Disabled Veteran Owned Small Businesses (i.e., collectively Small Business Concerns), shall have the maximum practicable opportunity to provide goods and services to the University.

Reason(s) for the Policy

For contracts over a certain dollar threshold awarded by the federal government, a formal plan is required outlining purchases with Small Business Concerns for various categories of spend under the contract.

Primary Guidance to Which This Policy Responds

This policy is promulgated in accordance with Executive Order 11246 and Public Law 95-507 of the Federal government and their implementing regulations.

Responsible University Office and Officer

Responsible University Office: Purchasing

Responsible University Officer: Manager, Small Business Compliance and Vendor Outreach

Revision History

This policy revises the policy on Small Business Concerns located in the Purchasing Policies and Procedure Guidelines (Appendix 9), dated March 10, 2005.

Who is governed by this Policy

This policy applies to everyone working at the University, or working on behalf of the University, who manages any aspect of purchasing activity with University's federal funds.

Exclusions and Special Situations

This policy applies to all locations or organizations (internal or external to the University).

Policy Text

Public Law 95-507 passed in 1978 amended Section 8(d) of the Small Business Act of 1953 and created the foundation for the Subcontracting Assistance Program as it is known today. The term Subcontracting Assistance Program and Subcontracting Plan applies to prime contractors and subcontractors to the federal government. It changed the participation of large contractors in the program from voluntary to mandatory, and it changed the language of the law from "best efforts" to "maximum practicable opportunities." Other key features include a requirement that all federal contracts over the simplified acquisition threshold as stated in Appendix A, as amended, provide maximum practicable opportunity for small and small disadvantaged businesses to participate.

See full policy text