In order to participate in the Veterans First Contracting Program, a business must be verified through the Department of Veterans Affairs’ VetBiz Vendor Information Pages (“VIP”) Verification Program. This is popularly referred to as “VetBiz.”
As a veterans lawyer and veterans advocate, I hear a lot of veteran business owners complain about VetBiz. They vent on LinkedIn forums, complain amongst themselves, and see the application process as a confusing ordeal. And now, for the first time, they have an opportunity to effect change by commenting on the VA’s advanced notice of proposed rulemaking to the regulations governing VetBiz.
So why aren’t they speaking up?
In a June 18th VetForce meeting in Washington, D.C., a representative from the VA relayed that only seven sets of comments have been received by the VA thus far. Of the thousands and thousands who have run the VetBiz gauntlet? How is that possible?
Here’s one explanation: they may be waiting until close of the due date of July 12 to comment. As we all know, when a due date is imposed, people like to cut it close. Also, since veterans service organizations write on behalf of all members of the organization, it might take a while for them to compile the input received.
Here’s another explanation: they may not think their comments will matter. It takes a while for change to be effected in government; and just because a suggestion is made, that doesn’t mean it will be followed. So why not just continue to fire away on LinkedIn? I’ve seen those group discussions, and they’re very interactive. In contrast, commenting on a regulation may seem like talking to a wall, or like there’s little chance of it creating change.
The issue, however, is this: if veteran business owners don’t comment, there is no chance of effecting change. A voice isn’t heard if it stays silent.
Also, in this case, the VA wants to hear them. It understands that its verification process is still undergoing growing pains and that veteran business owners are frustrated. The VA wants to know what it can do to make its regulations clearer and the process less cumbersome.
If you’re considering commenting on the regulations, maybe this will motivate you: on June 27, I submitted comments on behalf of my company, and I found plenty to say based on my practical experience with the VetBiz process. For example, these are my suggested verification process improvements:
- Include help buttons for each relevant document, addressing common issues that require Letters of Explanation. For example, if a veteran business owner clicks on the help button over “resume,” it could note that a Letter of Explanation is needed if the resume uploaded lists outside employment.
- Substitute “N/A” for certain Letters of Explanation, as some are unnecessary and create additional work.
- Create a process tracker where veteran business owners could access to determine where their application stands in the process.
- Enable veteran business owners to remove old documents from their VetBiz portal, upon reapplication. Allowing these documents to remain is confusing, and, to a degree, unfair – these businesses are required to wait six months for a new shot at the application process.
- Modify the “submit” button, as it is much too easy to accidentally submit an application before the veteran business owner is truly ready to do so. (It is the same color and size font as the “next” button on prior pages).
There are less than two weeks left. If you feel strongly about something related to VetBiz, make a comment! It’s simple – go to http://www.regulations.gov and search for the rule using the identification number VA-2013-VACO-0004-0001; RIN: 2900-AO63. You will access a page where you can enter or upload your comments. (All in all, it took me less than three minutes to fill in the required company information and upload mine).
Legal Meets Practical, LLC’s comments to the rule can be accessed here: VOSB_Reg_Comments_LP. Also, my earlier blog entry announcing and providing information about the proposed rulemaking is here.
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I have submitted everything they wanted and then they keep wanting more! There is no reason I need to submit more checks proving I pay rent on a monthly basis when I have sent them my PnLs. I need upper management involved.
I know VetBiz is still undergoing “growing pains,” but some of the experiences of veteran business owners are so very frustrating – if you are asked to provide A, B, and C, you shouldn’t later get a request that they also need P, Q and R!
You’re not alone here. I don’t know ANY veteran business owners who have been through the process who have not been required to submit additional documentation after hitting “submit.”
On a more positive note, hopefully veteran business owners applying three years from now won’t have this same experience – CVE does seem amenable to suggestions, and the predetermination initiative is great progress. (No business should have to go through a request for reconsideration because of a single issue in its operating agreement).