Contracting officers who already have an SBIR relationship with a small business often ask a practical question: can follow-on work be awarded as Phase III without running a new full competition? In many cases, yes, when the work is a Phase III extension of prior SBIR effort and the statutory path is documented.

This article explains how to award SBIR Phase III follow-on work to a small business, using WANDR’s Air Force SBIR path as a concrete example. It is not legal advice. Your agency counsel and the SBIR policy guidance you already use should review the justification. The broader practice is on our government digital transformation page. If you want to talk through a specific requirement, book a Government Discovery Call with Lina Silva, CEO, who is WANDR’s government point of contact.

What SBIR Phase III follow-on work is

SBIR Phase I is a feasibility effort. Phase II is a prototype or development effort. Phase III is work that derives from, extends, or completes prior SBIR effort, funded with non-SBIR money. Phase III is the follow-on stage, not a new research topic.

Agencies can award Phase III work to the SBIR awardee that did the prior work, including through a vehicle such as a BOA, without opening a new full competition, when the Phase III conditions are met. That is the path contracting officers use when they need to continue work that already has SBIR past performance, rather than starting over.

WANDR’s Air Force SBIR path

WANDR is a SBIR Phase I, II, and III awardee on Air Force work: Phase I FA8649-19-P-A317, Phase II FA8649-20-C-0099, and Phase III 47QFRA21C0005. The Phase III engagement has continued beyond contract completion into an ongoing relationship with the U.S. Air Force. Agencies can award follow-on work directly as Phase III through the BOA, with no new full competition, when that path applies to the requirement.

That past performance supports sole-source justification for Air Force, Space Force, and interagency partners when the work derives from, extends, or completes that SBIR effort. It does not mean every requirement at every agency is automatically a Phase III award. The work and the justification still have to line up.

What a contracting officer should have in the file

A clean Phase III file usually includes:

  • The prior Phase I, II, and (if any) Phase III award numbers and a short description of the work performed.
  • A statement of how the new requirement derives from, extends, or completes that SBIR effort.
  • The funding source (Phase III is not paid with SBIR R&D set-aside funds).
  • The vehicle you will use, including a BOA or other Phase III vehicle when one is in place.
  • The small-business status and identifiers you need for the award: for WANDR, UEI Q6JEHT3Z7XG3, CAGE 8CAY9, and NAICS 541512, 541511, and 541330.

If Phase III is not the right path for a given requirement, other award paths may still be available, including a WOSB set-aside or a subcontract to a prime. Those are described on our government digital transformation partners page.

What kind of work can sit on a Phase III follow-on

For WANDR, Phase III follow-on work has been digital transformation work that extends the Air Force engagement: systems and workflows a program team can use, including Microsoft 365, SharePoint, and Power Platform when those are the right path, and custom development when they are not. The through-line is work that continues the mission function, not a new commercial pitch disconnected from the prior SBIR effort.

If the follow-on increment is a Power Platform application or a SharePoint migration, see Power Platform consulting services for government. The award path and the government practice still start on the government digital transformation page.

How to start

Bring the requirement, the prior award numbers if you have them, and the outcome you need. We will tell you whether Phase III follow-on looks like a fit, or whether a WOSB set-aside or a subcontract is the cleaner path.

Book a Government Discovery Call with Lina Silva: lina@wandr.studio, (323) 690-7705.