VetLikeMe, November 6, 2014
CVE “White Paper”
DEPARTMENT OF VETERANS AFFAIRS
Center for Verification and Evaluation
U.S. Department of Veterans Affairs | 810 Vermont Avenue, NW
Washington DC 20420
Phone: (866) 584-2344
Email: [email protected] |
Over the past two years the Center for Verification and Evaluation (CVE) has undergone a remarkable transformation. This transformation has occurred throughout the organization and is continuing today.
Changes have been dramatic and very beneficial to the veteran entrepreneur community. A quick review of CVE verification statistical data helps to provide a frame of reference for what has occurred.
During Fiscal Year 2012, CVE took an average of 87 days to make an initial determination for firms applying for verification with completed application. Currently, utilizing FY 2014 data, the average time for CVE to render an initial determination is 35 days, a reduction of over 60% in less than two years.
Similarly, comparing Requests for Reconsideration (R4R) to reconsider denied applications, the average processing time in FY 2012 was 92 days. Current R4R processing averages 19 days for determinations, a 78% reduction in processing time. These performance numbers are well below the 38 Code of Federal Regulations, Part 74 regulatory guidelines of 60 days for application processing, when practicable.
Increased Opportunities for Verification:
CVE has introduced two new processes to increase success and enable veteran entrepreneurs avoid denial of their applications. The Pre-Determination Findings process allows a veteran owner an opportunity to correct minor deficiencies which would otherwise lead to an application denial. CVE notifies the veteran of the specific issues, and will continue the application process upon correction. If the modifications satisfactorily resolve the issues of concern, an approval letter will be issued.
The Pre-Decision Process addresses more complex problems with an application which cannot be remedied quickly. Again, CVE notifies the veteran owner of these issues in detail, affords the owner the opportunity to withdraw the application to correct these issues, and then reapply, thus avoiding the six month penalty for being denied.
Communications with Veterans:
CVE continues to update the information provided on the web site, by expanding its Frequently Asked Questions (FAQ) and Verification Fact Sheets to provide additional information and clarifications about the verification process. CVE has expanded the capabilities of its telephone help desk, and added new outgoing calls to assist and guide veterans at critical steps in the process or to provide individual insights to our process and head off emerging issues.
Today, as a general observation, CVE is making more outgoing, proactive calls to veterans than the numbers of inbound calls and queries it receives. We reach out 4 months ahead of time to all verified firms in order to remind them of pending expiration, and followed up with monthly notifications until the firms reapplied or expired. CVE has also greatly expanded its presence and information flow by means of social media. With active Twitter, LinkedIn and Facebook accounts with well over 1,500 followers, CVE reaches out with information and updates daily to interested veterans. CVE’s goal is to provide information and assistance to assist all veteran owners at every stage in the process.
Verification Counselor Assistance to Applicants:
The Department of Veterans Affairs and CVE have established a written cooperative agreement with the Defense Logistics Agency to provide no cost counselling service and assistance to all veteran business owners across the country and in US territories. With this agreement, every business counsellor in every Procurement Technical Assistance Center (PTAC) nationwide will be trained and certified by CVE to inform and assist veterans in the application process and other matters in business dealings with the federal government. CVE has already trained and certified over 270 counsellors in every state and territory, and is striving to achieve a goal of 400, which would represent all counsellors at PTACs. This no cost benefit is available to all veteran business owners today.
Updating the Verification Rules in Code of Federal Regulations (CFR):
CVE has initiated a process to update and improve the CFR which governs the VA Verification process. CVE has involved key veteran stakeholders at every step in this process to gather input, recommendations and assist in making the new CFR rules synchronize with current common business practices. The proposed rule has been posted and circulated for comments; feedback incorporated, and CVE will soon be completing the regulatory process for legal reviews and implementation. In jointly working these rule improvements, the Veteran Community spoke, and CVE listened to cooperatively make needed improvements.
Preventing Fraud and Protecting the Veteran Advantage:
CVE recognizes the delicate balance between expeditiously verifying veteran owned businesses and preventing illegitimate businesses from gaining contracts improperly. CVE has increased its on-site audits significantly to visit businesses and make sure they continue to meet the program core tenets of eligibility, ownership, and control. Through modeling and business intelligence tools and working closely with the VA Inspector General and contracting offices, CVE seeks to identify and exclude ineligible businesses from taking contracts away from verified businesses which continue to meet the program requirements. This is a very difficult challenge which CVE has addressed aggressively.
This is not to say the CVE transformation has been without issues. The results of an August 2012 General Accounting Office (GAO) audit indicated that the CVE IT infrastructure was not up to the task of managing an expanded federal wide verification effort and that upgrades were needed.
Accordingly, the VA Office of Information Technology (OIT) undertook a contractual effort to develop and field the Veterans Enterprise Management System (VEMS), a multimillion dollar replacement of the current CVE case management software.
Unfortunately, this development encountered technical challenges resulting in cancellation of the contract. As an interim measure, CVE has embarked on an upgrade to the current IT systems until a fully modernized system can be fielded. This will be transparent to veterans and will enable CVE to efficiently manage most tasks effectively.
CVE has made great strides in improving the verification process and service to veterans. (VA leadership recently recognized CVE’s accomplishments and progress over these past two years, and the VA Chief of Staff cited and thanked the organization and its personnel for these many improvements earlier this month.)
Communications and collaboration with veterans are open and transparent; assistance programs are expanded and are free for veterans, and new, more business friendly rules and guidelines are on the way. Fraud prevention measures are in place and have been expanded in numerous areas. Internal training for CVE personnel is continuous and focused on enhancing accuracy and the customer experience. Nevertheless, CVE’s leadership will not rest on their laurels, and has pledged to continue to make steady improvements throughout the CVE organization.
Note: This copy of CVE’s White Paper differs from the original in page numbering only. Original: http://vetlikeme.org/docs/CVE-White-Paper-Oct2014.pdf
One Vet Responds to the CVE “White Paper”
Jim Sechrist responds to the CVE “White Paper”
“Several days ago, I was asked to read and comment on a “White Paper” published by the VA CVE Office for FY 2014. I almost choked when I read it, especially page 4 of the Summary. It reads: “CVE has made great strides in improving the verification process and the service to veterans.”
This statement is true and false:
- There are more than 5000 firms registered as verified SDVOSB firms. That’s very difficult to believe;
- Several SDVOSB firms are registered twice as verified. Many have only one employee winning contracts worth millions of dollars. Others have minority owners controlling the SDVOSB firm.
- Many SDVOSB are registered as A & E firms but — on closer examination — are subcontracting 100% of the contract. This violates Federal Acquisition Regulation 52.219.14.Several firms had been removed from the program after finding them controlled by a non-SDVOSB firm. Many of these companies reappeared on the VETBiz Information Pages shortly thereafter.
- Many SDVOSB are located at the same business address as the firm using them as a “pass through.” Many of those businesses have telephone numbers listed on the VETBiz vendor page, but Google reveals a different address. One firm has been awarded $50 million in contracts set-aside for SDVOSB firms.
- According to my research, at least a third of these firms are “Rent-a-vet” or “pass-through” companies for other businesses.”
- Contributed by Jim Sechrist (Note: image shown is not Mr. Sechrist)
Editorial—CVE’s White Paper
By Sarah Schauerte, Esq.
For a while, my blog has been pretty grim. With everything going on regarding the scandals involving VA medical care, and the disability claims backlog, and the growing pains of the CVE, writing hasn’t been particularly fun. As a veterans advocate, I’d much rather report on positive developments, because it means we’re getting somewhere.
And finally, it looks like we might be getting somewhere. And it’s certainly worth a blog post.
Any business that wants to do business with the VA in the Veterans First Contracting Program has to be listed in the Center for Verification and Evaluation’s (CVE’s) VetBiz registry. In the years since the CVE’s inception, businesses have had a hard time going – the regulations are difficult to understand (especially in the absence of bright line rules), application examiners have differing levels of understanding, technicalities have caused denials, and wait times (particularly for requests for reconsideration) have been so long that businesses have lost out on valuable contracts.
Recently, however, I gained access to a white paper produced by the CVE, which is scheduled for posting on the CVE’s website in early November. Don’t get me wrong – the CVE has a long way to go – but this is a step in the right direction. I think that some of the improvements identified in the paper are a bit overstated, but it reflects that significant improvements have been made in the last few years:
- Increased Opportunities for Verification – The white paper notes its new pre-determination and pre-decision processes. Thank goodness these have been implemented, as the request for reconsideration process was a “one shot” deal that often resulted in a business having to wait six months to reapply. While I don’t think these processes are without their problems, I’d much rather see businesses going through pre-determinations or pre-decisions rather than requests for reconsideration. The wait times are much shorter, and the ability of a business to “withdraw” means they can immediately reapply.
- Communications With Veterans – The white paper also points out the “great expan[sion]” in communications with veterans. I’ve heard numerous veterans note this improvement, which includes calling businesses prior to verification expiration and after document requests. While some of the information contained in these communications may not be helpful in the event a veteran needs nuanced guidance, it does give veterans direction to seek assistance (such as through counselors or attorneys/consultants).
- Verification Counselor Assistance – This was the one part of the white paper I almost wholly disagreed with. (However, this should be qualified by the fact that I went through the training to become a certified counselor in February of 2012 – hopefully the counselor training has become more rigorous by then). The white paper noted that there are 270 counselors in every state, all of whom are listed on the CVE’s website. These counselors are available for free to veteran businesses seeking verification. While many of these counselors are well-qualified with the best intentions, it should be noted that counselor training involves a one-day course that focused primarily on the process of verification, not the details that prevent businesses from becoming verified. Counselors – to my knowledge – do not receive updates on the process. Nor are they required to complete continuous education. Thus, while these counselors do want to help veterans, the fact of the matter is there may be improvements necessary for them to truly guide veteran business owners through the process.
- Updating the Verification Rules in the Codes of Federal Regulations – The regulations applicable to VetBiz are contained at 38 CFR Part 74. The CVE is in the process of updating and improving these, which would go a long way towards providing much-needed clarification. (For example, the regulations do not address pre-determination and pre-decision). I do wonder when we can actually see these changes take place, as discussions regarding these changes have been underway for a few years now. Accordingly, don’t expect a rule change any time soon.
- Preventing Fraud and Protecting the Veterans Advantage – This is done primarily through increased random site visits. I know of a few companies that have been the subject of these lately, and there doesn’t seem to be rhyme or reason for their selection. This means that a mom-and-pop company might run the gauntlet, spend hours preparing documentation…and then get unlucky six months later. I’m all for audits and measures to detect fraudulent companies, but I’d like more explanation for why certain companies are chosen.But this white paper is at least a step in the right direction. I’m still going to blog on the issues – as veterans have the right to know – but being an advocate doesn’t mean that I’m wholly negative. I’m glad to report on the positive too.* Did you find this article informative? If so, sign up for Sarah Schauerte’s legal blog on veterans business issues at: http://www.legalmeetspractical.com
- This is a democracy! Comment on what you think of this white paper. Have you seen positive changes at the CVE?
- Years ago, when the Small Business Administrations 8(a) BD program was going through its growing pains, it wasn’t exposed to social media – attacks on Twitter, LinkedIn, blogs, etc. The CVE is one of the first certification program to be exposed as such, which is unfortunate especially given that it is truly experiencing growing pains. Businesses have denied when they shouldn’t have been, wait times have been long, and the CVE is still struggling to find the right balance between preventing fraud and not imposing overly harsh requirements.
Are These Personal Demons Sabotaging Your Success?
While there’s no magic bullet for success, there’s also no shortage of books and articles instructing others what they “must do” to be successful. I happen to find it equally valuable to share with people what they absolutely cannot do if they aspire to reach their full potential on both a personal and professional level.
In my list of potential “success killers,” the naughty demons of fault and blame most certainly hold the top positions. This isn’t because they’re the worst personal demons we face, but they do tend to be the most prevalent and the most ignored.
The ability to become successful and reach full potential requires that we first obtain two critical building blocks for our foundation: POWER and CONTROL.
I’m not referring to the power and control we exercise over others, but the type we exercise over ourselves. It guides our self-discipline, and speaks to issues such as responsibility and accountability. It’s the type of power and control that gives us mastery over our own momentum.
Fault and blame serve no other purpose than to transfer rightful ownership of control from one person to another. As a consequence, those who transfer control to another person end up losing it themselves instantly.
The “Blame Game” may appear to have the superficial benefit of deflecting judgment and consequence, but that ends up being nothing more than temporary. The price paid for that decision is a complete surrender of power, control and authority – all of which are required components for success at any level.
In the words of Pulitzer Prize-winning author Alice Walker, “The most common way people give up their power is by believing they don’t have any.” The second most common way people give up their power is by voluntarily giving it away via fault and blame.
Conversely, the same thing happens when those with a victim or martyr mindset assume fault and blame erroneously. We all have people like this in our professional circles. They’re easily identified by phrases such as “I know I didn’t cause it to happen but it’s still my fault … I should have known better and seen it coming.”
That’s ridiculous. Unless, of course, your job title is “Psychic” or “Emotional Piñata.”
There are times when you can make all the right decisions and do all the right things, yet still lose to some degree. That falls into the category of “things happen,” and assuming blame for events completely outside of your control is equally as destructive as blaming others for your actions.
I will also state without hesitation that assigning blame and fault is pointless even when it is justified. If you’re not correcting a problem quickly as a result of being preoccupied with blame and fault, the problem still exists and poses a challenge that needs to be resolved.
If you’re in a boardroom, that type of decision can prove to be embarrassing. If you’re running your own business, it can be financially disastrous. And if you happen to be on a battlefield, it can prove to be deadly.
Identify the problem, correct it, learn from it and move on. Benefit from the experience and leave the “blame game” to career politicians. The short-term pain associated with making mistakes and accepting responsibility is not nearly as painful as handing over your power and control (and subsequent success) to someone less deserving than you.
“Fault” and “Blame” are personal demons that subvert success by stripping their practitioners of power and control. Drag these demons out of the cave, into the sunlight and see them for what they truly are and what they truly do to your personal and professional potential. Cast them out of your life forever.
Those who continue to use these two nasty demons as a shield of protection will eventually realize that they didn’t pass the buck; they passed the torch of success to someone with the power and control to carry it to the end of the race.
Michael Kaplan is a military veteran, serial entrepreneur and author. If you enjoyed this article, see his most recent book: The Prior-Service Entrepreneur: Providing Military Veterans with the Competitive Skills to Start a Successful Business. You’re invited to connect with Michael on Twitter and Facebook as well.
Three mistakes that can derail older entrepreneurs
More boomers are launching their own businesses. Why they have a much better success rate than others, what you need to consider before launch, and the biggest mistakes people make, with Sharon Epperson.</p>
Launching a business—whether it’s a side hustle or second career—is on the minds of many people these days, especially baby boomers. As they get ready to retire, or are laid off, more and more baby boomers are feeling the entrepreneurial spirit.
Research from the Kaufmann Foundation shows those who are 55 or older have the highest rate of entrepreneurship in America, and they’re almost twice as likely to be successful as those in their 20s and 30s. But starting a business certainly has its challenges.
Senators squabble over pace of reform at VA
WASHINGTON — New VA Secretary Bob McDonald promised to have his scandal-plagued agency on the road to recovery by Veterans Day, but there is growing frustration among Senate Republicans over a perceived lack of progress as the date approaches.
Sen. Richard Burr, R-N.C., the ranking lawmaker on the Veterans Affairs Committee, on Tuesday joined with fellow senators John McCain and Jeff Flake to criticize the secretary for “ongoing failures” such as keeping disgraced Phoenix VA director Sharon Helman and other executives linked to wrongdoing on the payroll.
Veteran Entrepreneurs Honored During National Veterans Small Business
Week, November 3-7
FORT WORTH—The accomplishments of Veteran small business owners around the country will be celebrated during National Veterans Small Business Week (NVSBW) November 3-7. U.S. Small Business Administration district offices and resource partners nationwide will host more than 100 local events, including entrepreneurship training such as Boots to Business: Reboot classes, veteran access to capital workshops, and government contracting roundtables.
Jax business settles claim it took contracts designated for disabled vets
Jacksonville, FL — Profiting at the expense of disabled veterans- it’s the claim from the Department of Justice about a Jacksonville-based company.
WOKV has obtained a settlement agreement between North Florida Shipyards and the US over claims that Shipyards used a “front company” to win contracts from the Coast Guard that were designated for businesses owned and managed by disabled veterans. The Shipyards is paying $1 million to deal with the allegations while, for the most part, not admitting guilt.
Pair conspired to obtain government contracts
by Daniel Leaderman Staff writer
A California man has pleaded guilty for his role in a fraud scheme that also involved a Gaithersburg business owner.
Between 2007 and 2014, Wesley Burnett falsely told the federal government that his security company was owned by a minority, owned by a veteran disabled in the service, and was a “small disadvantaged business” to obtain about $534,000 in government contracts set aside for such businesses by the Small Business Administration, according to his plea agreement.
Letter from a VetLikeMe reader regarding VA inaction on documented fraud in the VA/SDVOSB program:
“Eugene Ogozalek, a combat wounded Marine, Purple Heart recipient, verified SDVOSB owner, and licensed architect in Pennsylvania, has been told by a subcontractor working on the Wilkes-Barre, VA medical center in Pennsylvania, that the SDVOSB general contractor on site performs little or no work with his own forces and subs out all the work to non-SDVOSB contractors. In addition, the general contractor’s project manager has been caught watching porn during the day in the job site office, and is generally unresponsive to field questions referring those questions to other subs.
The general contractor, Hamilton-Pacific-Chamberlain of Maryland, is currently under investigation by the department of Veterans Affairs for violations of the SDVOSB regulations.
Mr. Ogozalek, as a CVE verified SDVOSB architect, has over the last several years, unsuccessfully attempted to investigate several other suspected Rent-A-Vet firms performing architectural and engineering work at the VA in Wilkes-Barre, including Bray Mooney, LLC, and Northeast Infrastructure, LLC.
Key information has been specifically redacted by the VA which would substantiate fraud as submitted on their federal 330 submissions. This redaction obfuscated the investigation to confirm the allegations of fraud by these companies.
As a result of his efforts to expose fraud, Mr. Ogozalek’s firm has not been short listed or considered for any additional work at the Wilkes-Barre VA, notwithstanding that his firm is located less than twenty miles from the Wilkes-Barre VA medical center. Mr. Ogozalek as a licensed architect for 38 years, is the only 100% owner of a duly registered architectural firm in Pennsylvania that is verified by the CVE as a SDVOSB company.
Mr. Ogozalek can only conclude that he has been blacklisted by the Wilkes-Barre VA for his attempts at exposing fraud in the SDVOSB architectural engineering services field.
In addition, Mr. Ogozalek is a patient at the facility, and continues medical treatment there for recurring symptoms associated with his combat injuries sustained over forty years ago as a U.S. Marine rifleman in Vietnam in 1968. Mr. Ogozalek was medically discharged from the Marines only one year after enlisting due to his serious injuries including a penetrating head wound caused by North Vietnamese artillery. Mr. Ogozalek served with India Company, Third Battalion / Fourth Marines, 3rd Marine Division in Vietnam, 1967-68.
Most recently, the VA on Wilkes-Barre has awarded a $600,000 design contract to a firm to design a new parking garage yet that firm has no registration as an architectural or engineering firm in Pennsylvania. Federal regulations mandate that any firm awarded architectural or engineering services is required to be “permitted by law to practice architectural or engineering services “.
Mr. Ogozalek has filed a complaint with the Pennsylvania Architectural board against this firm for practicing architecture without a license and has requested a cease and desist order against this firm.
Needless to say, Mr. Ogozalek is completely frustrated with the blind eye being turned to violations of state and SDVOSB regulations by the Wilkes-Barre VA. He has asked us to print these frustrations to bring them to light and is ready to substantiate all these claims if necessary directly with the VA in Washington, DC.”
Open Letter (e-mail) to VA about Blatant Fraud
SUBJECT: “Fraudulent company gets another 1.5 million dollar contract while a half dozen protests await SBA, GAO and VA process.”
VA has just awarded another $1,455,780.00 MILLION DOLLAR contract to G & C Fab-Con for concrete grave liners. As I would imagine, everyone within the VA knows G&C Fab-Con has somewhere in the area of a dozen protests pending before the VA, SBA and GAO and that’s just what I am aware of with my limited resources. How is it possible that VA can award another 1.5m to this company with all the “issues” so many different companies, individuals, service organization and others have brought to VA attention about this company alone? THIS IS UTTER MADNESS.
Last month alone VA awarded over 50 million in contracts to this FRAUD, Rent-A-Vet and SHELL company. I must point out that this 50 million dollars is just the money’s and contract I can find, again with my limited means and public records. I am aware that every single one of those contracts are under protest. How is it possible that VA leadership has failed to at least put a hold on any future contracts until all those pending legal matters are resolved? That would be common sense would it NOT? What message are you all sending, again, to those who are following the laws, procedures and doing all the right things to comply with the SDVOSB program when VA leadership awards ANOTHER couple million to a company with so many massive issues to address???
What message are you sending to all VA employees here? Are you saying “…it’s okay to award regardless of very serious protests pending…”? Doesn’t it stand to reason that anyone should stand up and say “add this award to the list of protests” or are you all just assuming it’s okay because it’s done on the 5 year multi-award contract this FRAUD has with VA? Are you guessing no one can protest this one or is the VA simply trying to give this FRAUD as many contracts as possible before they are removed from CVE and handed over to the VA Office of the Inspector General?
Okay how about if VA gave the Veteran community a straight and legitimate answer here. Why are you awarding millions to a company under so much “review” by so many federal agencies? Is anyone really in-charge here, is anyone really watching what’s happening here…does anyone at VA really care? This is just so unbelievable that one must consider WHY it continues to happen. Is the VA system so screwed up and broken regardless of the massive backlash toward this one company? One would think VA would open its eyes but that’s just not the case and NOTHING has or will change at VA until and unless the entire broken system is completely dismantled.
Lastly, if this were just a single time it happened that would be one thing but it goes on every single day. Let’s use Legion Construction as a prime example. This company is going to trial for stealing over 180 million by defrauding Disabled Veterans as a Rent-A-Vet and scamming the system set-up to help Veterans…VA continues to hand them millions in contracts and calls it “MODS” or extra work or change orders. That’s the same as giving a sex offender awaiting trial a job at a day care! And VA leadership lets it happen day after day and nothing changes. This is so shameful and embarrassing that I can’t find the words to truly explain the unimaginable frustration and loss of hope the mass of Veterans feel. If not for the proof no one would believe this happens every single day. If nothing else this is morally wrong.
I am begging you on behalf of so many Veterans/Disabled Veterans…stop this insanity.
Twenty-two Veterans commit suicide every day…we need real leadership and legitimate action and we need it now.
Douglas P Fleming, LLC
Service Disabled-Veteran Owned-Small Business
Expressed opinions do not necessarily represent those of VetLikeMe
Supporting veteran entrepreneurs isn’t just the right thing to do for our vets – it’s the right thing to do for our nation.
The military trains soldiers with the skills, discipline and leadership necessary to kick start and operate a successful business. After serving in the military, many veterans return home and choose to run a business. As small business owners, veteran entrepreneurs are able to pursue their passion to serve our country by creating jobs and spurring economic growth. Veterans possess the skills, discipline, and leadership necessary to kick start and operate successful businesses. This week we honor veteran business owners with National Veterans Small Business Week.
With over 21 million veterans in America and more than 250,000 service members transitioning from the military annually, SBA is focused on ensuring that they have access to the capital, counseling, and contracting needed to start and grow successful businesses.
Veteran business owners…
- Are responsible for nearly one out of every ten small businesses in America
- Employ nearly six million workers
- Generate over 1.5 trillion dollars in receipts each year
- Are 45 percent more likely to be self-employed than non-veterans
National Veterans Small Business Week Events
SBA Resources for Veteran Entrepreneurs:
- Business Resources for Veterans Video
- SBA’s Office of Veteran Business Development
- Boots to Business
- Veteran Women Igniting the Spirit of Entrepreneurship
- Entrepreneurship Bootcamp for Veterans with Disabilities
Social Media Engagement
For National Veterans Small Business Week, SBA has created the hashtag #MyVetBiz to encourage veteran business owners to share their stories and to encourage community members to highlight local veteran-owned businesses in their community and show their gratitude and support. We’d love for you to join the conversation.
Hardy Stone is the editor/publisher of VetLikeMe, the nation’s only publication devoted to service disabled veteran owned business.