The Veteran Verification Process

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  • 1. The Veteran Verification Process Presented by MN PTAC Mark Cooper – Veteran Specialist 1-612-259-6578 1
  • 2. Agenda • Federal Registrations • VetBiz Registration • CVE – Veteran Verification a) Process b) Documents c) Compliance • Overview of Veteran Contracting Program 2
  • 3. Federal Registrations First Step: Get Registered The two required registrations: 1. Dun & Bradstreet – DUNS number – For problems AFTER - call 1-866-705-5711 2. Create an account in SAM; Migrate your Legacy Account (old CCR file) by calling FSD at 1-866-606-8220 or create a New Entity profile 3. DSBS – SBA Dynamic Small Business Profile (Old Pronet) accessible only through SAM 3
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  • 5. What is a Veteran Owned Business? What makes a Business truly Veteran Owned? 5
  • 6. A small business that is unconditionally owned and controlled by one or more eligible veterans, service- disabled veterans or surviving spouses: 6 • Day-to-day management means supervising the executive team, formulating sound policies and setting strategic direction. • Day-to-day operations mean the marketing, production, sales, and administrative functions of the firm. • not less than 51 percent of which is owned by one or more service- disabled veterans • Not subject to Negative control : this includes, but is not limited to, instances where a minority shareholder has the ability, under the concern's chapter, by-laws, or shareholder's agreement, to prevent a quorum or otherwise block action by the board of directors or shareholders
  • 7. If these basic eligibility requirements aren’t met, it may/will result in immediate denial of your verification application: 7 • The Veteran or service-disabled Veteran must be the highest ranking officer • The Veteran or service-disabled Veteran owner must be the highest compensated employee of the applicant, or provide an explanation as to how taking lower compensation is beneficial to the applicant • Full Time Control (An owner engaged in employment or management outside the applicant concern must submit a written statement supplemental to the application which demonstrates that such activities will not have a significant impact on the owner’s ability to manage and control the applicant concern.) • Transfer of Ownership and Control Within Two Years of Application: Non-Veterans who transfer majority stock ownership or control of the firm to an immediate family member within 2 years prior to the application and remain involved in the firm as a stockholder, officer, director, or key employee of the firm are presumed to control the firm
  • 8. These government entities will accept your CVE Veteran Verification  MNDOT  Dept. of Veteran Affairs  State of MN Materials Management Division  MCUB (Metropolitan Council Underutilized Businesses)  Stadium Commission Why Get Verified? 8
  • 9. Veteran Verification Process Center for Veteran Enterprise (CVE) 9
  • 10. 10 READ THESE!
  • 11. Verification Assistance Briefs  Verification Assistance Briefs on VETBIZ  Link: ◦ Board Governance ◦ Demonstrating control ◦ Trusts ◦ Transfer Restrictions ◦ Joint Ventures ◦ Full Time Control ◦ Fast Track ◦ Community Property  Seek partnerships with VSOs and other support organizations ◦ Training ◦ Counseling 11
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  • 17. Click on “NEXT” at bottom of the page 17
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  • 20. After downloading correct business entity document use “Register” button to return to register page 20
  • 21. Proper labeling is important for upload! Scan each document separately, and label as shown! 21
  • 22. account profile, once complete, will look similar to CCR managemen IF THIS “STATUS” SAYS “ACTION NEEDED” OR “REQUESTS” YOU MUST CLICK ON IT AND FIND OUT WHAT THE VA IS TRYING TO TELL YOU 22
  • 23. You can see and access everything you uploaded 23
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  • 25. VetBiz Verification Examination • CVE performs a document review of all information on the company • Documents provided by applicant are examined and rated against the Risk Matrix • Examiners contact the company for additional documentation, if needed, and to clarify questionable items in the documentation • Upon completion of the examination, the examiner makes a recommendation of approve, deny, site visit or further review and returns the file to CVE. 25
  • 26. VetBiz Verification Evaluation • The CVE staff Quality Reviewer (QR) receives the file and reviews the documents and examination report to verify that the analysis was correct. If discrepancies are found, all documents are thoroughly checked. • QR makes an approval, denial, or more evaluation required determination 26
  • 27. VetBiz Verification Evaluation – Further review recommendation • Applications recommended for further review go to the Risk Management Team • Risk Team performs a detailed review of the entire file • Further documentation may be requested and reviewed • If required, a Site visit is scheduled 27
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  • 29. VetBiz Verification Evaluation –Site Visit • If the Risk Management Team determines that a complete picture of the company can’t be made based on the documentation submitted, a site visit is scheduled • Site visit examiner does a complete review of the documentation before visiting the company • Examiner makes recommendation to Risk Management team based on the results of the site visit 29
  • 30. Site visit Preparation See Handout Sheets 30
  • 31. VetBiz Verification Determination • Once examination and site visits are complete, the evaluation team evaluates the file and makes a determination • All determinations are made by CVE Federal employees • Denial recommendations are based on either a single point of failure (Critical on the Risk Matrix), or on a totality of circumstances • The determination letter is signed and emailed to the Veteran within two business days. • Approved companies have their verification logo turned on and now appear in VIP. • Denied companies have 30 days to file a request for reconsideration 31
  • 32. VetBiz Verification Issues that may cause delays • Submission of material or requests that are outside the accepted process • Not checking the appropriate box for “status” on the VA Form 0877 • Not indicating percentage of ownership for each individual owner • Ownership total does not equal 100% • Not listing all owners • Business name “Name of Company” on VA Form 0877 doesn’t match the business name listed in the Vendor Information Pages profile or D&B, or SAM or the Secretary of State filings (all must be the same) 32
  • 33. Issues that may cause delays • Veteran’s name doesn’t match Veterans Benefit Administration records (Veteran record hasn’t been updated with VBA, i.e., name change due to marriage) • The applicant does not provide complete, correct documentation • The applicant has an unusual ownership or management structure • The applicant has affiliation issues • The Veteran is unavailable or unresponsive to requests for further information. VetBiz Verification 33
  • 34. • Quorum Restriction CFR § 74.4(f); 38 CFR § 74.4(f)(2)(i) • Weighted Voting Requirement 38 CFR § 74.4(f)(2) • Day-to-Day Operations 38 CFR § 74.4(b) • Management of Daily Business and Full-time Devotion During Normal Working Hours 38 CFR § 74.4(b)(3) • Minimum Documents Required for Examination 38 CFR § 74.3 • Ownership 51% Unconditional 38 CFR § 74.4(e) • Community Property 38 CFR § 74.3(f) • Dependence with other entities 38 CFR § 74.4(i)(4) • Control of Strategic Policy 38 CFR § 74.4(e) • Highest Officer Position § 74.4(g)(3) 34 Top 10 Reasons for Denial in August 2013
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  • 36. Veterans Benefits, Health Care, and Information Technology Act of 2006 Public Law 109-461, the Veterans Benefits, Health Care, and Information Technology Act of 2006, was signed into law by President Bush on December 22, 2006. This law provides VA with unique authority to conduct set-aside and sole source procurements with Small Businesses owned and operated by Veterans. Download VA Acquisition Circular 2008-01, which implements the “Veterans First Contracting Program” (P.L. 109-461). Executive Order 13360, Contracting with Service-Disabled Veterans’ Businesses On October 20th, 2004, the President signed Executive Order 13360 calling for an increase Federal contracting and subcontracting opportunities for Service-Disabled Veteran-Owned businesses. On December 12th, 2004, the Executive Office of the President issued a memorandum to all Federal agencies on the implementation of the Executive Order. This memorandum provides guidance to assist agencies in preparing their strategies to implement the Order. Among other things, the Executive Order requires each agency to: Develop a strategy to significantly increase its contracting and subcontracting with Small Businesses owned and controlled by Service-Disabled Veterans; Designate a senior-level official to be responsible for developing and implementing the agency’s strategy; and Report its progress annually to the Small Business Administration (SBA). Veterans First Program - VA 36
  • 37. 1. Redefines priorities for contracting preferences within VA, placing SDVOSBs and VOSBs first and second, respectively, in satisfying VA’s open market acquisition requirements. 2. Allows sole source contracts over the Simplified Acquisition Procedures Threshold up to $5,000,000 (including options). 3. Implements restricted competition via Set-Aside Procedures for each category of SDVOSBs and VOSBs. 4. Allows additional credit evaluation factors for SDVOSB or VOSB status. Benefits of Veterans First Buying Authority 37
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  • 39. Questions???? Need help? Call Mark Cooper Or Contact your closest PTAC counselor 39