6.  What significant alternatives were considered that accomplish the stated objectives and minimize any significant economic impact on small entities?

DoD, GSA, and NASA minimized the significant economic impact on small entities. Pursuant to section 8(m) of the Small Business Act, a WOSB concern may be certified by a Federal agency, a State government, or a national certifying entity approved by the SBA; or a WOSB concern may self-certify to the contracting officer that it is a small business concern owned and controlled by women, along with adequate documentation in accordance with standards established by SBA. As discussed earlier, EDWOSB and WOSB concerns are allowed to self-certify their status in CCR and ORCA databases or provide evidence of certification from an approved third-party certifier.

Therefore, although there may be some overlap, the addition of the set-aside mechanism for WOSB concerns should complement rather than conflict with the goals of existing set-aside programs.

An alternative approach would have been to require EDWOSB and WOSB concerns to apply for formal certification. This alternative approach was ruled out as unnecessary, not required by statute, and too costly. DoD, GSA, and NASA believe that eligibility examinations and protest procedures incorporated into this interim rule will minimize the likelihood of fraud and misrepresentation of WOSB and EDWOSB status. DoD, GSA, and NASA have decided that allowing self-certification and the option for firms to apply for certification from SBA-approved certifiers, when combined with random eligibility examinations and a formal protest procedure, is a more viable approach than formal certification and greatly reduces the burden on small entities.

In addition, DoD, GSA, and NASA estimate that implementation of this interim rule will require no additional proposal costs for WOSB concerns, as compared to submitting proposals under any other small business set-aside preferences. Moreover, WOSB concerns currently represent their status for purposes of data collection that is needed to implement 15 U.S.C. 644(g); therefore, the self-certification process of this interim rule imposes no additional requirement on WOSB concerns.