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RHINOCORPS, LTD., APPELLANT

SBA No. NAICS-47362005 WL 3008172October 7, 2005

SBA No. NAICS-4736 (S.B.A.), 2005 WL 3008172

Small Business Administration (S.B.A.)

Office of Hearings and Appeals

[North American Industry Classification System]

*1 RHINOCORPS, LTD., APPELLANT

*1 Docket No. NAICS-2005-09-08-48

*1 Solicitation No. W91QF4-05-R-0011

*1 U.S. Army Contracting Agency

*1 Northern Region Contracting Center

*1 Fort Leavenworth, Kansas

*1 October 7, 2005

Appearance

*1 Anthony Contri, Esq.

*1 President

*1 RhinoCorps, Ltd.

*1 Appellant

DIGEST

A procurement for (1) Maintenance/enhancement of program databases; (2) Administrative support of conferences; (3) Software support of modeling and simulations for wargaming/combat programs; and (4) Provision of systems engineering and analysis for military exercises is appropriately classified under North American Industry Classification System (NAICS) code 541511, Custom Computer Programming Services, with a corresponding $21 million annual receipts size standard.

DECISION

PENDER, Administrative Judge:

Jurisdiction

*1 This appeal is decided under the Small Business Act of 1958, 15 U.S.C. § 631 et seq., and 13 C.F.R. Parts 121 and 134.

Issue

*1 Whether a procurement for: (1) Maintenance/enhancement of program databases; (2) Administrative support of conferences; (3) Software support of modeling and simulations for wargaming/combat programs; and (4) Provision of systems engineering and analysis for military exercises is appropriately classified under North American Industry Classification System (NAICS) code 541710, Research and Development in the Physical, Engineering, and Life Sciences or 541330, Engineering Services, or some other NAICS code.

Facts

*1 1. On August 30, 2005, the U. S. Army Contracting Agency, Northern Region Contracting Center in Fort Leavenworth, Kansas (“Army”), issued Request for Proposals No. W91QF4-05-R-0011 (“RFP”). The purpose of the procurement is to provide support for the mission of the U.S. Army Training and Doctrine Command (“TRADOC”) Analysis Center (“TRAC”) at White Sands Missile Range, New Mexico (“WSMR”). The Procuring Contracting Officer (“PCO”) restricted competition to small businesses and designated North American Industry Classification System (“NAICS”) code 541710, Research and Development in the Physical, Engineering, and Life Sciences, which has a 500 employee size standard.

*1 2. The RFP provided the Army would award the successful offeror an Indefinite Quantity type contract for non-personal services. The RFP (Section B, paragraph B. 1.b) stated the Army would award all contract services by issuing firm, fixed price Task Orders using loaded labor rates established in the contract.

*1 3. Section B, paragraph B.10., contains the Contract Line Item Numbers (“CLINs”) where the offerors are to propose prices for the basic contract and options. The Army separated the CLINs by labor categories with an estimated number of hours placed next to the type of labor. Offerors are to propose an hourly rate, multiply the total estimated hours by the rate, and write in the total the amount for each rate. Offerors are also required to propose an hourly overhead rate separate from that total dollar amount for each rate. There are no specific labor categories for scientists or engineers.

*2 4. The total number of labor hours for the CLINs together is approximately 212,000 hours. The largest CLIN category (25,140 hours per year) is for “Computer Op III/Asst Tech Ed.” Total Computer Operation hours is more than 37,000 hours. There are also large numbers of estimated hours for Project Leaders, OR/SAs (Operations Research /Systems Analysts - 28,000), S/W Analysts (Software Analysts - 32,000), Combat Operations Analysts (36,000), and Simulator Interactors (30,000). These labor categories account for 78% of the 212,000-hour total.¹

*2 5. This Office requested the Independent Government Estimate (“IGE”) from the PCO, which he provided. The IGE contains the Government's estimated hourly rates for the labor categories found in the CLINs. The IGE is necessarily source selection sensitive and I cannot reveal specific information contained therein.

*2 6. Section C of the RFP contains the Performance Work Statement (“PWS”). The PWS describes the work the offerors are to accomplish and the requirements for the labor categories. In addition, the PWS describes qualifications for the labor codes listed in the CLINs.

*2 7. Paragraph C.1., states “The Contractor shall provide personnel expertise and skills required to accomplish TRAC-WSMR missions related to analysis, studies, modeling, simulation, and Information Technology.”

*2 8. Section C, paragraph 2.3 states that Contractor personnel are to “provide technical capabilities as members of the TRAC study/modeling teams for the planning and conduct of analyses and studies, the development and improvement of combat models, computer operations and maintenance, and display of data through multimedia and production projects.”

*2 9. The PWS lists two base tasks under paragraph 3.1. The first requires the Contractor to maintain, enhance, and perform a quarterly update of an automated program database. The second base task is for the Contractor to provide administrative support for TRAC sponsored conferences - to include all presentations, coordination, invitations/conference information, and preparation of facilities for two to three conferences per year.

*2 10. PWS paragraph 3.1.3. is entitled Modeling and Simulation. It contains subparagraphs that describe the work the contractor must accomplish under this heading and identifies the modeling programs TRAC uses. Its first requirement is that the Contractor will support the development, maintenance, and enhancement of certain named analytical models (paragraph 3.1.3.1.). This effort requires software development activities, including system and data analysis, system programming, and database and application prototyping. It also requires other computer/software skills and significant knowledge of Army policies, doctrine, concepts, tactics, techniques and procedures. The Contractor is also required to provide configuration management (“CM”) support, which, in this context, appears to be a requirement to track changes to software or database baselines (paragraph 3.1.3.2.).

*3 11. PWS Paragraph 3.1.4. and its subparagraphs, describe effort associated with Scenarios, Wargaming, Exercise and Experimentation Support, and Analysis. These paragraphs describe how the contractor is to utilize its experience, in “... combination with OR/SA techniques, to conduct analyses of Doctrine, Organizations, Training, Materiel, Leadership and Education, Personnel, and Facilities.” Other detailed requirements include conducting gaming exercises and providing systems engineering and analyses for military exercises and experiments.

*3 12. Following the text of subparagraphs 3.1.3.1. through 3.1.4.5. are charts that identify what contractors are to accomplish in performing Models and Simulations, Scenario and Wargaming Production, Analysis and Development, Other, Network Management, and System Administration tasks. Underneath each chart is the labor category the Government believes will be associated with these tasks. There is a significant emphasis on computer usage/operation, programming, etc., skills to perform the contract. The PWS Systems Administration Tasks diagram focuses the contractor on performing computer operation and software tasks, e.g., SW development-modification-testing-troubleshooting-administration. According to the charts, software skills are required to perform the Models and Simulation, Network Management, Systems Administration, and Other Tasks. The Scenario and Wargaming Production, Analysis and Development Tasks will require the Operations Research/Systems Analyst (“ORSA”), Combat Operations Analysts, and Simulator Interactor /Trainer skills.

*3 13. PWS paragraph 5.1. provides:

*3 Special Knowledge And Experience. The Contractor's full-time and part-time staff must be knowledgeable and experienced in the following areas: DA and joint policies, doctrine, concepts, tactics, techniques, and procedures. Experience is also required in ORSA of large, complex databases, modeling, and simulation of operations from small unit through division and corps including advanced information and simulation technologies guiding Army research and development and acquisition decisions, scenario wargaming, and graphical user interfaces, and art and design. Additionally, knowledge and experience in computer support, information management, security administration, and supply operations is required ....

*3 14. PWS paragraphs 6.1. through 6.14. describe the tasks and qualifications required of the labor categories listed in the CLINs. The categories all require subject matter training, knowledge, or experience. However, apart from specific experience and knowledge, the labor categories typically require skills in computer gaming, simulations, operations, security, software design, and software testing. In short, even though knowledge of Operations Research/Systems Analyst, Combat Operations, Army doctrine, tactics, force structure, communications, training, emerging threats, and the ability to train is required, use and familiarity with computer systems is inherent to perform the contract.

*4 15. Section M of the RFP contains the evaluation factors for award, which are:

*4 1. Overall Technical Approach

*4 2. Experience and Technical Qualifications of Personnel

*4 3. Organization and Management

*4 4. Past Performance - Corporate Background, Experience, and Performance

*4 Factors #1 and #2 are equal in importance and twice as important as factors #3 and #4, which are equally important.

*4 16. Evaluation Factor for Award #4 has nine Subfactors. Of these nine, five relate directly to computer hardware and software experience or skills, i.e., software engineering, systems administration, computer systems and database development, management, and administration, computer graphics, information, personnel and physical security.

Appellant's Appeal and Argument

*4 On September 8, 2005, RhinoCorps, Ltd. (“Appellant”) filed an appeal, asserting that the appropriate NAICS code for the procurement should be 541330, Engineering Services, with a corresponding $4 million annual receipts size standard. Appellant asserts that this code has a $23 million annual receipts size standard, but that is only under the sub-codes, Military and Aerospace Equipment and Military Weapons, and Contracts and Subcontracts for Engineering Services awarded under the National Energy Policy Act of 1992. See 13 C.F.R. § 121.201.

*4 Appellant asserts other solicitations for similar procurements to support TRAC have not used NAICS code 541710, but rather, have used NAICS code 541330. Appellant further asserts this RFP stems from a procurement for support at WSMR, which the Army originally classified under NACIS code 541330 and does not have substantially different requirements from this RFP. In addition, Appellant points out the Army announced a sole source contract extension to the TRAC WSMR incumbent contractor with NAICS code 541330.

*4 Appellant argues persuasively that the support services the Army seeks here to procure are not Research and Development as envisioned in NAICS code 541710. As it points out, the RFP calls for assistance with the TRAC's operations research activity providing analyses, studies, modeling, and simulations for military operations. The RFP requires the contractor's personnel to be knowledgeable and experienced in Army policies, doctrine, concepts, tactics, and procedures as well as operations research and systems analysis. Thus, there is no requirement they utilize physical, engineering, or biological sciences in laboratories to develop products, as does the Army Research Laboratory.

*4 Appellant asserts this RFP seeks to procure operations research (the discipline of applying advanced analytical techniques to help make better decisions and to solve problems) wargame modeling, analyses, studies, and simulations. Appellant argues these services are not research and development. These activities, Appellant argues, are properly characterized as applied engineering support, not research and development.

*5 In its September 21, 2005, Motion for Summary Decision, Appellant argued that the Army's reply to an information request by this Office prove NAICS code 541710 inapplicable. Specifically, Appellant urges this Office find that the Army's characterization of the RFP's purpose as “to provide professional, scientific, and technical support to TRAC-White Sands Missile Range, NM.” (emphasis added by Appellant) means NAICS code 541710 is plainly wrong.

*5 Appellant asserts this Office should apply NAICS code 541330 to this procurement. The logic Appellant offers is that since the Army has historically used NAICS code 541330 for similar efforts, it should use it for this RFP.

Procedural Matters

*5 This Office originally assigned this case to Judge Christopher Holleman. The Assistant Administrator later reassigned this case to me. 13 C.F.R. § 134.218(a).

*5 Appellant filed a Motion for Summary Decision on September 21, 2005. Since I believe its motion is not appropriate, as may be discerned from the Discussion below, it is DENIED.

*5 On October 3, 2005, I held a conference call with the Army (Mr. Robert Knopp) and Appellant (Mr. Anthony Contri). During that call, I informed both parties I believed the NAICS codes each proposed were incorrect as a matter of law. I requested the parties to suggest to me an appropriate code after discussing the matter with each other. The Army and Appellant have reasonably informed me they do not believe they can do that.

DISCUSSION

*5 Appellant filed the instant appeal within 10 days after the Army issued the solicitation. Thus, the appeal is timely. 13 C.F.R. § 134.304(a)(3).

*5 Appellant has the burden of proving, by a preponderance of the evidence, all elements of its appeal. Specifically, it must prove the PCO based his NAICS code designation on a clear error of fact or law. 13 C.F.R. § 134.314. The correct NAICS code is that which best describes the principal purpose of the product or service being procured, in light of the industry description in the NAICS Manual,² the description in the solicitation, and the relative weight of each element in the solicitation. 13 C.F.R. § 121.402(b).

*5 The NAICS code designated by the PCO, 541710, covers:

*5 [E]stablishments primarily engaged in conducting research and experimental development in the physical, engineering, or life sciences, such as agriculture, electronics, environmental, biology, botany, biotechnology, computers, chemistry, food, fisheries, forests, geology, health, mathematics, medicine, oceanography, pharmacy, physics, veterinary, and other allied subjects.

*5 NAICS Manual, at 745.

*5 “Research and Development” means laboratory or other physical research and development. It does not include economic, educational, engineering, operations, systems, or other nonphysical research; or computer programming, data processing, commercial and/or medical laboratory testing. 13 C.F.R. § 121.201, fn. 11(a).³

*6 This RFP is not about the conduct of research or of experimental development in the physical, engineering, or life sciences to provide a product or service. None of the labor categories identified within the CLINs and discussed in the facts above, even require experimentation or work by scientists or engineers to develop a product or service (Facts 3, 4, 6, 7, 8, 9, 10, 11, 12, 13, and 14). Instead, in large part, this procurement requires skills specifically excluded from this NAICS code by Footnote 11 to 13 C.F.R. § 121.201, which excludes the computer skills.

*6 Our previous decisions support this analysis. The predecessors of this NAICS code under the Standard Industrial Classification (SIC) system were various codes dealing with research and development, including 8731, Commercial Physical and Biological Research. NAICS Manual (1997),⁴ at 881-882.

*6 This Office has found physical research SIC codes were applicable to procurements for scientific and technological support for an ongoing drug abuse and drug addiction research program; a research laboratory involved in the development and testing of biological systems for military aircraft; and technical services to support research and development of aerospace and guided missile systems. SIC Appeal of Braton Biotech, Inc., SBA No. SIC-4180 (1996); SIC Appeal of Engineering Spectrum, Incorporated, SBA No. SIC-3899 (1994); SIC Appeal of Malcolm Thomas Industries, Inc., SBA No. SIC-3667 (1992).⁵ However, we found the code was inapplicable to procurements for support services for a center for the assessment of reproductive health risks, which would not include research; and for the evaluation of research, as opposed to the research itself. SIC Appeal of Information Ventures, Inc, SBA No. SIC-4259 (1997); SIC Appeal of The Cadmus Group, Inc., SBA No. SIC-3315 (1990).

*6 In Cadmus, this Office held that these codes included basic research, defined as the continuing search for new knowledge with only the direction of the researcher himself; applied research, defined as laboratory studies concerning the practical application of new knowledge; and development, which takes applied research out of the laboratory and translates it into production. SIC Appeal of The Cadmus Group, Inc., SBA No. SIC-3315, at 8-9 (1990). Accordingly, I find NAICS code 541710 does not have a substantial relationship to the services/products the Army seeks to procure in the PWS for this RFP.

*6 The Appellant urges NAICS code 541330. It covers:

*6 [E]stablishments primarily engaged in applying physical laws and principles of engineering in the design, development, and utilization of machines, materials, instruments, structures, processes, and systems. The assignments undertaken by these establishments may involve any of the following activities: provision of advice, preparation of feasibility studies, preparation of preliminary and final plans and designs, provision of technical services during the construction or installation phase, inspection and evaluation of engineering projects, and related services.

*7 NAICS Manual, at 745.

*7 Examples include civil engineering services, construction engineering services, environmental engineering services, mechanical engineering services, and engineers' offices. Id.

*7 In arguing this Office should apply NAICS code 541330 for this RFP, Appellant offers no meaningful analysis or discussion about why the code is correct. Instead, it simply asserts the Army has used this code for these kinds of services before. However, evidence concerning these codes and the PWSs for these procurements have not been offered to or provided to us and are not part of the record in this case. Accordingly, I cannot consider them. See 13 C.F.R. §§ 134.306(b), 134.315, and 134.316. Moreover, although the Army may have used NAICS code 541330 for similar procurements in the past, this does not place any stamp of validity upon its use, for Appellant does not assert this Office has ruled upon its use in those instances.⁶

*7 I find that NAICS code 541330 is plainly incorrect for this RFP. This RFP has nothing to do with the application of physical laws and engineering principles to the design, development, and utilization of machines, materials, and instruments, structures, processes, and systems. The PWS does not require or suggest the contractor is to use engineering principles to provide what the RFP requires. Rather, there is only incidental language that says computer engineering degrees may fulfill an educational requirement for the Systems Administrator labor category (PWS paragraph 6.9.2.). That is hardly unusual, for many Systems Administrators are computer engineers.

*7 This Office has ruled on matters that have some relevance to this RFP and code 541330. As mentioned, the predecessor of NAICS codes were SIC codes. Under the SIC system, the predecessor to NAICS code 541330 was SIC code 8711, Engineering Services. NAICS Manual (1997), at 879. This Office has held that this code covers procurements for engineering services for radar systems; engineering and computer services for the testing and evaluation of prototypes; engineering services for an electronic systems center; and engineering in support of military equipment. SIC Appeal of Eagle Systems, Inc., SBA No. SIC-3901 (1994); SIC Appeal of Challenger Engineering, Inc., SBA No. SIC-3711 (1992); SIC Appeal of Advanced Testing Technologies, Inc., SBA No. SIC-3687 (1992); SIC Appeal of America House, SBA No. SIC-3659 (1992). This Office has never held this code has anything to do with the kind of “soft” sciences prevalent in this RFP and I will not do so here.

*8 To review, the NAICS code the PCO designated, 541710, covers research and development in the physical, engineering, and life sciences, and does not cover procurements which, while they may be related to such research, do not actually call for it. That is because the code only covers laboratory or other physical research and development, not non-physical research, such as the type called for in the RFP. Appellant's requested NAICS code, 541330, covers engineering services, involving the design and utilization of machines, materials, and systems. That is likewise inappropriate.

*8 The PWS for this RFP is diverse. It requires many different skills, including Program Management, Project Leadership, Operations Research/Systems Analysts, Combat Operations Analysts, Simulation Interactors, Software Computer Analysts, and Systems Administration. The commonality between all of these labor categories is that working with computer software and hardware is integral to their ability to perform the contract (Facts 8 - 15). Moreover, for approximately 92,000 of the 212,000 yearly estimated hours (including management hours), writing software, operating hardware, maintaining hardware, and managing a computer system is their primary function. (Note labor categories 110, 111, 112, 113, 117, 118, 119, 120, 121, 122, 123, and 124 in the CLINs.)

*8 Other important categories, both in terms of effort and estimated hourly rate also require substantial computer software effort and focus - beyond the point where expertise in that area is simply a tool.⁷ Expertise with and the ability to develop software and fully use computer resources is inherent in these labor categories. For example, PWS paragraph 6.1.2. contains the education and experience requirements for the Senior Program Manager. This person is specifically required to have technical and management experience that includes systems analysis, systems design, software and systems development, systems integration, application development, test and evaluation, etc.

*8 The PWS identifies other labor categories where advanced software and computer skills are required. One is the education and experience requirements for the Operations Research/Systems Analyst (OR/SA) labor categories (labor categories 104, 105, and 106-28,000 hours). These individuals, at all levels, besides having subject matter experience, must develop, validate, and maintain state-of-the-art computer combat models and wargames (Facts 11 and 12; see PWS paragraph 6.4.1.).

*8 A further example of computer focused labor categories are the Simulator Interactors (labor categories 114, 115, 116, - 30,000 hours). These labor categories, among other things, conduct research for loading on a database; provide exercise support using Janus and other computer models and simulations; translate and convert field directives and maneuvers into required computer models and simulations; and conduct combat simulation using premier Army interactive models. Plainly, capability to work with computer software and hardware at an advanced level is critical to the function of Simulator Interactors.

*9 The Combat Operations Analyst labor categories also have requirements to work extensively with computer wargames [programs] and simulations (labor categories 107, 108, and 109 - 36,000 hours). PWS paragraph 6.5.1. and the task chart make it plain these individuals will work extensively with computers to perform their functions.

*9 It is also probative the PWS identifies CM as a responsibility of the Contractor (Fact 10). This particular requirement is normally associated with deliverable products such as computer software or complex manufactured products a contractor changes or modifies as it performs the contract.⁸ Here, the PWS makes it plain the Contractor will be developing or modifying software as the contract progresses. This makes CM relevant.

*9 In noting the amount of labor category efforts with a substantial relationship to computer software usage or expertise, it is also important to recognize the Evaluation Factors for Award in Section M of the RFP further support the premise that working with computers is vital to the procurement. While the first three evaluation factors do not address PWS requirements, the fourth factor does under Past Performance. Of the nine Subfactors listed, five are directly connected to the computer services, i.e., Software Engineering, Systems Administration, Computer Systems and Database Development, Management, and Administration, Computer Graphics, and Information, Personnel, and Physical Security. What is more, the Subfactors for Technical Writing and Office Management and Research Analysis also have a strong relationship to computer services.

*9 My analysis shows that approximately 75% of the total labor category hours listed in the CLINs are either directly related or strongly related to the provision of computer software, modification, testing, or supporting services. Further analysis shows that a very substantial portion of the IGE relates to the provision of computer software, modification, testing, or supporting services. In addition, computer software and other services was the part of the PWS most specifically identified in the Evaluations Factors for Award. I therefore find that NAICS code 541511, Custom Computer Programming Services, with an annual size standard of $21 million, is the proper designation for this RFP.

*9 In making this determination, I have considered Facts 1 - 16, the entire PWS, and the Independent Government Estimate. It is my opinion they show the weight of this procurement is for the provision of services directly related to computer software and support services. This determination is consistent with NAICS code 541511, which provides:

*9 [E]stablishments primarily engaged in writing, modifying, testing, and supporting software to meet the needs of a particular customer.

*9 NAICS Manual, at 738.

*9 In this case, the successful offeror will be writing, modifying, testing, and supporting wargaming and simulation software so the Army (the particular customer) can run wargames and simulations for WSMR. This expertise, along with knowledge of the Army mission, is critical for performance of the contract. Absent the computer software expertise and knowledge, the contractor would not be able to perform the work required in the PWS. Quite simply, the method of delivering the service - computer software and hardware has graduated from being merely a tool. The Army requires contractors to be expert in writing, modifying, testing, and supporting software as an integral and essential part of providing services required by this RFP.

*10 This Office has recently decided a case involving this Appellant with similar facts and found that NAICS code 541690 applies. NAICS Appeal of RhinoCorps, Ltd., SBA No. NAICS-4729 (2005). However, the present facts are sufficiently different as developed herein to justify the use of NAICS code 541511, for this RFP's successful offeror will be providing the Army services that go far beyond Scientific and Technical Consulting Services or expertise.⁹ In this RFP, the contractor will undoubtedly provide expertise, but that expertise will have no value if it the contractor cannot write, modify, test, and support existing and new software and hardware. Thus, it is my view that the inherent nature of this procurement is such that NAICS code 541511 is the code that best describes the principal purpose of the services the Army is procuring, in light of the industry description in the NAICS Manual, the description in the RFP, and the weight of the labor categories in the RFP. See 13 C.F.R. § 121.402(b).

*10 Accordingly, I conclude that Appellant has met its burden of establishing error in the PCO's designation of NAICS code 541710 for this procurement. However, I find the appropriate NAICS code is 541511, with a corresponding $21 million annual receipts size standard. Appellant's appeal is SUSTAINED.

CONCLUSION

*10 The appropriate NAICS code for this RFP is 541511, with a corresponding $21 million annual receipts size standard. The PCO's designation is REVERSED, and the instant appeal is GRANTED as provided herein.

*10 This is the Small Business Administration's final decision. 13 C.F.R. § 134.316(b).

*10 Thomas B. Pender

*10 Administrative Judge

Footnotes

The OR/SAs include three different categories, i.e., Senior OR/SA Study Lead, Senior OR/SA and OR/SA. The others include more than one category as well.

Executive Office of the President, Office of Management and Budget, North American Industry Classification System Manual (2002).

Some NAICS codes are further defined in SBA's size regulations, which provide additional criteria for classifying procurements under those NAICS codes. NAICS Appeal of Prudent Technologies, Inc., SBA No. NAICS-4710, at 5 (2005).

Executive Office of the President, Office of Management and Budget, North American Industry Classification System Manual (1997).

Decisions of this Office decided under the SIC system are applicable to NAICS code appeals. NAICS Appeal of Phoenix Scientific Corporation, SBA No. NAICS-4416, at 8 (2000).

See NAICS Appeal of RhinoCorps, Ltd., SBA No. NAICS-4729 (2005), where this Office found NAICS code 541330 was not applicable under similar facts.

Cf. NAICS Appeal of Eagle Design and Management, Inc., SBA No. NAICS-4510 (2002). In that case, this Office found the computer work was a tool. In this instance, the computer effort is so integral to the entire effort it is beyond being a tool.

Configuration management requirements are typical in contracts for complex software or hardware products. Configuration management is a key task, for it is how the Government tracks the evolution of the product so it can determine exactly what it is getting and how the product became what is delivered as it is modified and changed as the contract progresses.

The size standard for NAICS code 541690 is $6 million in annual receipts.

SBA No. NAICS-4736 (S.B.A.), 2005 WL 3008172

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