What is "Affiliation"

The Small Business Act of 1958, 15 U.S.C. § 631 et seq., and 13 C.F.R. Parts 121 and 134 describes "Affiliation".

https://www.acquisition.gov/far/97-15interim/pdf/19.pdf  

http://www.gpo.gov/fdsys/pkg/CFR-2010-title13-vol1/xml/CFR-2010-title13-vol1-part134.xml

What is an "ostensible subcontractor"

http://www.va.gov/vetbiz/acquisition/ostcn.htm

GTSI and the SBA

GTSIis classified as a Large Business under SBA Guidelines.  GTSI was profiting from skirting the Small Business Set-Aside Federal Contract Awards.  

The Email Illusion: GTSI not only was alleged to have been Affiliated with small business’, by the SBA, but it has been written in articles that GTSI went so far as to create email address domains, with similar email domains from Small Businesses, so as to make it appear as if the emails sent to US Government employees were in fact being sent from a Small Business. http://washingtontechnology.com/Articles/2010/10/04/GTSI-suspension-contracting-concerns-questions.aspx?Page=1

The Invoice Illusion:GTSI actively engaged in conduct concealing the extent of its involvement as a subcontractor ….[including such actions as] GTSI created invoices and placed the letterhead of the prime contractor on the invoice … so the invoice would appear to have been created by the prime contractor rather than by GTSI. Re. Liability of a False Claim by a Large Business http://apogeeconsulting.biz/index.php?option=com_content&view=article&id=443:gtsi-suspended-for-problems-with-small-business-set-asides&catid=1:latest-news&Itemid=55

The dilemma appears to be the Small Businesses allowing this to happen. It is extremely important for a Small Business to put up want ever defenses they can to prevent a Large Business from becoming “Affiliated”.  It doesn’t matter if the Surety or a Contracting Officer/s are the cause for “Affiliation”, a Small Business MUST prevent Affiliation!

 Notice of GTSI Suspension by SBA: http://www.govexec.com/pdfs/100510rb1b.pdf