Understanding GSA
and SBA MentorProtégé Programs
U.S. government agencies collectively have over a dozen mentor-protégé programs available to government
contractors. “Mentoring” is defined generally as a more experienced person advising or training a less
experienced person (the protégé) and helping them develop specific skills and knowledge which will help them
grow. In the government contracting arena, mentoring is raised to the company level.
If you’re involved in government contracting, you’ve probably at least seen references to mentor-protégé
programs that are offered to government contractors. What may have been unclear, however, is that both the
General Services Administration (GSA) and Small Business Administration (SBA) offer mentor-protégé programs
which are separate and distinct from each other.
In addition and as noted above, the other agencies throughout the federal government have mentor-protégé
programs which differ from both the GSA’s and SBA’s programs.
If you’re thinking that it would be great to have a single small business mentor-protégé program across all
government agencies, or at least standardized requirements, Congress recently took steps to try to ensure that
the SBA creates guidelines to assist the various agencies in that regard.
This white paper will briefly set forth the basic objectives and benefits of both the GSA’s and SBA’s distinct
programs. Then it will examine the impact which the National Defense Authorization Act of 2013 (enacted January
2, 2013) will have in attempting to standardize other mentor-protégé programs throughout the government.
GSA Mentor-Protégé Program
Started in September 2009, the GSA Mentor-Protégé Program (GSAMPP) was designed to encourage GSA
prime contractors (a large or small business) to assist small businesses in order to enhance the smaller
business’s capability in successfully performing on GSA contracts and subcontracts.
The goals of the GSAMPP are for the mentor to use the relationship to gain greater exposure to new technology
and business ideas, while the protégé increases the overall number of GSA prime contract and subcontract
awards it receives.
To qualify to apply to be a mentor, the company must be a prime contractor on a GSA Schedule or a GSA
contracting vehicle (for example, a blanket purchase agreement or government-wide acquisition contract
[GWAC]). For a contractor which is considered to be “large” (i.e., an other than small business), the contractor
must have in place under its contract an approved subcontracting plan; however, a small business prime
contractor is not required to have such a subcontracting plan to qualify as a mentor.
In addition, the prospective mentor must be able to guarantee that it is able to provide developmental assistance
to augment the protégé’s capabilities to perform as a contractor, subcontractor or supplier in the federal
contracting space. One particular benefit to large-size mentors is that the GSAMMP will help it achieve its
subcontracting plan goals.
In order to qualify as a protégé, the company need merely be a small business concern, as defined in the Federal
Acquisition Regulation (FAR) and established by the SBA. This includes disadvantaged small businesses,
women-owned small businesses, HUBZone small businesses, veteran-owned small businesses and servicedisabled veteran-owned small businesses.
In addition, the potential protégé must be a current subcontractor or newly selected by the potential mentor as a
subcontractor on its GSA contract.
Once the mentor and protégé have agreed to join forces, they will mutually create the application for mentorprotégé status, as well as a needs assessment for the protégé. These are submitted to the mentor-protégé
manager in the GSA’s Office of Small Business Utilization for approval; following approval, the two companies
draft and submit a mentor-protégé application agreement. When the agreement is approved and executed, the
mentor-protégé team has been formed.
Regulations contained in the General Services Administration Acquisition Manual (GSAM) set forth in more detail
what developmental assistance the mentor can provide, how the mentor-protégé program is measured for
success, what internal controls must be in place and even how the mentor or protégé can terminate the
GSA and SBA Mentor-Protégé Programs | ©Deltek 2013, All Rights Reserved
agreement, if necessary. These regulations are too detailed to recount here, but suffice it to say that there is
enough guidance to help ensure a successful program.
The GSA reported as recently as February 2012 that the GSAMPP had grown to about 80 companies. More
recently, sequestration and the threat of cutbacks in government funding and programs make this an even more
vital vehicle for mentors and protégés alike to gain an edge in securing government contracts.
SBA Mentor-Protégé Program for 8(a) Participants
SBA’s 8(a) Business Development Program is, in the words of the SBA website, a “business development
initiative that helps socially and economically disadvantaged Americans gain access to economic opportunity.”
Much like the GSAMMP, the SBA Mentor-Protégé Program (SBAMMP) has as its objective increasing the 8(a)
participants’ capability to compete for federal government contracts through assistance from the mentor.
Because of its place in the SBA, which focuses on small business issues, the SBAMMP permits the 8(a)
participant to be either a mentor or a protégé, although mentors may also be large businesses, former 8(a)
participants which have graduated from the program or current 8(a) participants who are in a transitional phase of
the program.
One of the requirements to qualify as a mentor is that it can, through “lessons learned” and practical experience
which it gained from the 8(a) program (or even through the general knowledge of government contracting it
already possesses), provide valuable support to the protégé during the course of the SBAMMP. The protégé, on
the other hand, gains from this support and access to the mentor’s capabilities, expertise and resources.
Once the mentor and protégé have qualified for the program, an agreement is entered into (and evaluated by that
protégé’s servicing district office) between them that (1) sets forth the protégé’s needs and (2) indicates what
assistance the mentor has agreed to provide to the protégé. The SBA thereafter conducts annual reviews in order
to determine if the mentor-protégé relationship is successful.
Alternatively, the mentor may, in some cases, enter into a joint venture agreement with the protégé in order to bid
on federal government contracts. Perhaps more importantly, the mentor may invest and own an equity interest of
up to 40% of the protégé, and up to a 49% profit interest in a federal contracting joint venture with the protégé,
without being deemed affiliated with the protégé for purposes of the SBA’s “affiliation rule.” This ability of the
mentor to invest in the protégé while not disqualifying the protégé from 8(a) program participation may help the
protégé in raising capital.
The National Defense Authorization Act of 2013 and MentorProtégé Programs
The Small Business Act of 2010 created a second SBA Mentor-Protégé Program (for convenience, referred to as
SBAMPP-II) that was intended to be similar to the SBAMPP discussed above, but for all small businesses (i.e.,
veteran-owned small businesses, women-owned small businesses and HUBZone small businesses).
Like the SBAMPP discussed above, the affiliation rule is to be waived for the mentor. However, the SBA never
issued, nor even proposed, regulations for the SBAMPP-II.
In the National Defense Authorization Act of 2013, Congress sought to remedy this by authorizing (but not
requiring) the SBA Administrator to issue such proposed regulations as they relate to the other agencies of the
government (except for the Department of Defense, which has its own mentor-protégé program) which have
mentor-protégé programs.
The SBA has 270 days from the date of enactment of NDAA 2013 to issue such proposed regulations if it decides
to issue them. The effect of the new NDAA law is that the SBA will set the guidelines and rules, including eligibility
and benefits for participation, for all other agency mentor-protégé programs (except the DOD), and ultimately
those agencies must submit their programs to SBA for approval.
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Congress also provided a roadmap for the SBA in what it expected to see in terms of the SBAMPP-II for all small
businesses. It is supposed to be “identical” to the SBA 8(a) program/SBAMPP; however, the SBA Administrator
can modify the SBAMPP-II to the extent necessary to allow for the types of companies which will be included to
qualify.
As of the date of publication of this white paper, these regulations have not yet been issued by the SBA. If and
when the regulations are proposed and finally adopted, each federal agency will have to submit its mentorprotégé program to the SBA for review and approval, with the SBA applying the guidelines and rules set forth in
the regulations and also determining whether the proposed plan will help the protégés compete for federal
contracts/subcontracts.
In addition, one year after the regulations are approved, any mentor-protégé program which is in place and has
not been approved by the SBA under the new rules will become invalid. At that point, theoretically, the uniformity
among different programs which some may desire will be achieved.
*******
This white paper is intended to provide a broad overview of the existing GSA and SBA mentor-protégé programs,
as well as some insight into how the new SBA program will work, if the SBA issues the regulations. It is not
intended to cover the detailed qualifications to be a mentor or protégé, or how the programs operate once they
are formed. If you’d like more details on these matters, contact WMG.
Contact a GSA or VA Schedule Consultant to Win More Business
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