A lot of small businesses do not realize they have a Build America, Buy America problem until a customer asks a painful question:
“Can you certify this is BABA-compliant?”
That is usually the moment the scramble starts. The buyer is already tied to a federally funded infrastructure project. The bid is moving. The project team needs documentation. And the supplier that thought it was “just selling parts” suddenly learns its product is being incorporated into a bridge, water system, broadband build, transit improvement, or other public infrastructure job that carries domestic content rules. By then, changing suppliers, rebuilding a bill of materials, or tracing where components were made can be expensive, slow, or impossible.
That is exactly why small contractors and suppliers need to understand BABA early, not after a compliance request lands in their inbox.
Why So Many Small Businesses Get Caught Off Guard by BABA
For many small businesses, the biggest issue is not intentional noncompliance. It is lack of visibility.
You may be selling parts, assemblies, fabricated materials, controls, or specialty products to a contractor, distributor, or manufacturer without realizing the end use is a federally funded infrastructure project. Then, once the buyer needs proof of domestic content compliance, they push that requirement down the chain. Suddenly, a business that never thought of itself as a government contractor is being asked to document where products were manufactured, where components came from, and whether the item meets Build America, Buy America standards.
By that point, the timing can be brutal. Pricing has already been submitted. Suppliers have already been selected. Lead times are already tight. If the product does not qualify, the buyer may have to replace it, seek a waiver, or move on to another vendor.
What Build America, Buy America Actually Covers
The Build America, Buy America Act applies to federal financial assistance for infrastructure projects in the United States. That means it is not limited to direct federal procurement contracts. It also reaches grants, cooperative agreements, loans, and other types of federal assistance when those funds are used for infrastructure.
This is an important distinction because many small businesses assume domestic content rules only apply when they are selling directly to a federal agency. That is not how BABA works. A company can be several steps removed from the government and still be part of a covered project.
The term infrastructure is interpreted broadly. Depending on the funding and agency, it can include things like:
Roads and highways
Bridges
Rail and public transportation
Airports and ports
Drinking water and wastewater systems
Utilities and electrical transmission
Broadband infrastructure
Buildings and public facilities
Energy generation and distribution systems
EV charging infrastructure
If federal assistance is helping pay for one of these projects, there is a good chance BABA requirements need to be considered.
What BABA Requires for Covered Projects
For covered infrastructure funding, the rule is that iron, steel, manufactured products, and construction materials used in the project must be produced in the United States unless a valid waiver applies.
That sounds simple until you get into the categories.
Iron and Steel
For iron and steel products, all manufacturing processes must take place in the United States, beginning with the initial melting stage and continuing through coatings and other required processing.
Manufactured Products
For manufactured products, the standard is generally two-part. The product must be manufactured in the United States, and the cost of U.S.-made components must be greater than 55 percent of the total component cost unless a stricter program-specific requirement applies.
Construction Materials
For construction materials, all manufacturing processes for the material must occur in the United States.
Why Classification Matters
One of the trickiest parts of BABA compliance is determining which category an item falls into. A product should fit into only one category, and the category affects what standard applies.
That means a supplier cannot assume all products are evaluated the same way. A metal-heavy item might trigger one analysis. An assembled device with multiple components might trigger another. Misclassifying the product can create serious compliance problems later.
Real-World Example: When a “Commercial Sale” Becomes a Compliance Problem
Let’s say you manufacture control housings, brackets, or specialty metal components. A regional fabricator buys from you regularly. From your perspective, it feels like a normal commercial relationship.
Later, you learn those parts are being incorporated into equipment for a federally funded bridge project.
Now your customer needs documentation showing whether your item meets BABA standards. They may need to know where the manufacturing occurred, whether the components meet the required domestic threshold, and whether the item was classified correctly. If you do not have those answers ready, your product may become a risk to the project.
Or imagine you distribute materials used in broadband deployment. You may think you are simply filling orders for a contractor. But if those materials are going into a federally supported broadband build, the project team may need documentation before installation or reimbursement.
These are the kinds of situations where small suppliers get blindsided.
The Timing Problem That Makes BABA So Dangerous
The biggest business risk with BABA is not just the rule itself. It is the timing.
By the time the compliance question is asked, the important decisions may already have been made.
Milestone 1: The Funding Is Already Covered
Build America, Buy America requirements have been in effect for covered infrastructure assistance since May 14, 2022. Since then, agencies have continued refining implementation through regulations, guidance, and program-specific procedures.
That means many active infrastructure awards already carry domestic content requirements somewhere in the chain.
Milestone 2: Award Dates Matter
The timing of the federal award or funding obligation matters because implementation rules evolved over time. Newer obligations are now governed under the current framework in 2 CFR Part 184.
For a small supplier, the practical takeaway is straightforward: do not assume a project is exempt just because it has been underway for a while. The funding path and award date matter, and your buyer may be working under rules that already require compliance documentation.
Milestone 3: Sourcing Decisions Happen Before Documentation Requests
This is where companies lose deals.
A buyer may not ask for proof of compliance until after pricing is submitted, procurement planning is underway, or materials are already being sourced. But domestic content compliance is not something you can always fix at the last minute.
If your supply chain is global and you have not mapped where manufacturing happens, you may have no way to support a certification. If the domestic content percentage misses the mark, you may need to redesign sourcing. If lead times are tight, switching vendors may kill the delivery schedule.
That is why BABA readiness needs to happen before the paperwork request, not after.
Some businesses assume that if a product does not qualify, the project owner can just request a waiver.
That is a risky assumption.
Waivers are allowed in limited circumstances, such as when applying the rule would be inconsistent with the public interest, when compliant products are not available in sufficient quantity or quality, or when using domestic products would increase project cost by more than 25 percent. But those waivers are not automatic. They require justification, review, and public transparency.
In practical terms, that means a waiver can take time your buyer may not have. If you are counting on a waiver to save a deal at the last minute, you may already be too late.
Why Highway and Bridge Suppliers Should Be Especially Alert
Some sectors have additional timing urgency because program-specific standards are tightening.
A major example is federal-aid highway and bridge work. For certain projects obligated on or after October 1, 2025, final assembly of manufactured products must occur in the United States. For projects obligated on or after October 1, 2026, those products must also satisfy the greater-than-55-percent domestic component cost standard.
That means businesses serving highway and bridge markets should not wait until 2026 to react. Buyers are already planning around those milestones now.
What Small Contractors and Suppliers Should Do Right Now
The good news is that BABA preparation is manageable when you start early.
Ask Better Questions Up Front
Do not wait for the buyer to bring up domestic content compliance. Ask whether your products are going into a federally funded infrastructure project. Build that question into quotes, order intake, onboarding, and sales conversations.
Map Your Supply Chain
You need a clear understanding of where final manufacturing occurs, where your major components come from, and how your products are likely to be classified under BABA. If you do not know that yet, now is the time to find out.
Organize Documentation Before It Is Needed
If a buyer asks for proof, you should not be starting from scratch. Build standard documentation processes now. Keep supplier certifications, manufacturing records, sourcing details, and product-level compliance notes organized and ready to share.
Review Product Categories Carefully
Do not assume every item is treated the same way. Some products will fall under iron and steel rules. Others will be manufactured products. Others may be construction materials. The category changes the compliance analysis.
Watch for Program-Specific Rules
BABA is a broad federal framework, but agencies and programs may have their own guidance, waivers, and implementation details. What applies under one funding program may not look identical under another. That is why staying informed matters.
The Bigger Business Lesson
The companies most likely to win in this environment are not just the ones with a good product. They are the ones that can answer compliance questions quickly and confidently.
That matters because buyers do not want uncertainty. If your competitor can provide clean domestic content documentation and you cannot, the buyer may choose the safer option even if your product is strong.
That is the real BABA lesson for small business suppliers. This is not just a legal or procurement issue. It is a business development issue, a sales issue, and a supply chain issue all at once.
If you wait until someone asks for proof, you may already be out of position.
Final Thoughts: Get Ahead of the Compliance Question
Build America, Buy America is affecting more small businesses than many owners realize. You may not think of yourself as operating in government contracting, but if your products are flowing into federally funded infrastructure projects, these rules can reach you.
And once that buyer asks whether you are compliant, the clock is already ticking.
Getting ahead of BABA means understanding where your products go, how they are sourced, and whether you can support your claims with documentation. It means treating compliance as something that needs to be built into your sales and supply chain process early.
If you need help identifying government contracting opportunities aligned with your business, or you would like a demo of FedBiz365—our AI-powered market intelligence tool that helps you quickly locate relevant opportunities and find contacts for government buyers purchasing what you sell—call FedBiz Access today: 844-628-8914 or book a call at your convenience.
Getting in front of the right opportunities early matters. Being ready for the compliance questions that come with them matters even more.
Mya works very accurately and delivers high-quality work in creating our Capability Statement for the GSA organization. Highly recommend her and her organization, FEDBIZACCESS.
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Sandra Chen
1 week ago
Ashley Futral is exceptionally helpful, knowledgeable, and a pleasure to collaborate with. Her efficiency and swift communication have been invaluable, and I greatly appreciate her guidance throughout the process.
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Jacqueline Winter
2 weeks ago
FedBiz makes renewals so easy and simple which is great as when doing it directly with the gov't is so much more complicated! It was great working with Ashley Futral on on our latest renewal - she saved me so much time! She also helped sort out issues that came up with SAM that I don't think we could have solved on our own. Thank you!
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Tara Goldsby
1 month ago
Ashley Futral was extremely helpful with renewing our sam.gov entity registration. She was always prompt with responding to emails and made the process go smoothly.
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Chris Ramey
1 month ago
Ashley is on another level!!! Very knowledgeable and helpful. Great to work with year over year!! Thumbs Up!!!!!!!
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Jay Reyes
1 month ago
Ashley Futral and the team at FedBiz Access provided outstanding support throughout my certification process. As the owner of a disabled veteran-owned logistics company, navigating the requirements can be complex—but Ashley made it seamless. Her professionalism, responsiveness, and deep knowledge of the process helped position my company for success in the government contracting space. Highly recommended for any business looking to grow strategically.
Response from the owner:Thank you for your service to our country. Our pleasure to assist and be of value to your organization in your government contracting goals.
Torland Wingfield
2 months ago
I had the pleasure of working with FedBiz on my SBA Disabled Veteran Owned Company Certification. Ashley was simply amazing, using her knowledge and professional approach to get the job done. She checked on me constantly providing weekly updates and worked all issues that came up during the process. I even received a call from her when the certification was approved. This is a great company that I give my strongest recommendation.
Response from the owner:Thank you for recognizing our FedBiz Access team's efforts on your behalf with this five star review and your positive feedback. We value your business and satisfaction.
Ice King LLC
2 months ago
Elizabeth Whitaker made our SAM renewal process quick and easy! We enjoyed working with her and the entire FedBiz Team. They have been great folks to work with and took sooooo much drama out of the process. Quick to respond to all our questions and we truly feel they want our business to succeed. Highly recommend !!!
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John Foster
2 months ago
Mya was great with communications throughout the project. She has outstanding graphics and document creation ability.
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Heridel Guadarrama
2 months ago
thanks Cassie for everything !!
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Jim Dragon
2 months ago
While working with FedBiz Access to update our cage code was an extremely easy worry-free process. Elizabeth was great to work with.
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Jon Urban
2 months ago
2025/2026 UPDATE: Cassie and her team at FedBizAccess continue to provide us with professional and reliable support for SAM registration and other government contracting needs.
2024 UPDATE: We continue to rely on FedBizAccess to help us stay on top of our SAM registration. Thanks again for making this an easy process for us, Cassie!
Original Review: We hired FedBizAccess several years ago to help us manage our federal contractor profile through the SAM database. Throughout the years they have been quick to respond to our requests. The past few years more of our focus has been outside the federal contracting arena and we hadn’t required their help. This year, though, we hit a snag renewing our SAM profile since we had a slight change in our company name. We reached out to FBA for help, and Cassie Elbanay responded immediately. She has been critical in helping us navigate the process. She is very knowledgeable, personable, and an overall professional. We are confident work will be done correctly and successfully when Cassie and her team are on the case. It has been a pleasure working with her, and I look forward to continuing our firm’s partnership with her and her team at FBA.
Response from the owner:Thank you for your time and effort in detailing your successful business relationship with our company and staff. Always here to assist as you need us. Thank you for your repeat business and this five star review for FedBiz Access, our amazing staff and your dedicated specialist. We appreciate your vote of confidence and the recognition of our expertise and long standing experience in the government contracting industry.
Alfonso Betts
2 months ago
Cassie Elbanay at FedBizAccess was extremely helpful in resolving my issue in SAM. Her knowledge and expertise with the SAM system made the process smooth and efficient—it was handled within minutes. It’s truly a pleasure working with such a knowledgeable and responsive team at FedBizAccess. I greatly appreciate the support and professionalism.
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Milissa Fowler
3 months ago
Cassie Elbanay was extremely valuable and I could not ask for an easier process. The amount of time and frustration she saved me was priceless. Amazing!
Response from the owner:Thank you for your amazing review and feedback. We aim for an easy and seamless process as much as possible. Thank you for your business and recognition of our FedBiz Access team specialist's efforts on your behalf. We appreciate it.
Joyce Kamau
3 months ago
Working with Cassie at FedBiz on our SAM registration renewal was a great experience. She was patient, thorough, and proactive in addressing potential issues before submission. Cassie expertise helped us avoid delays and ensured our registration was completed efficiently. Cassie is not only highly competent but also wonderful to work with throughout the process.
Response from the owner:Thank you for the detailed account of your great experience with the FedBiz Access team specialist and thank you for your repeat business. We value your feedback and strive to maintain this proactive approach for best and consistent results. We appreciate your recognition.
Brennan Champion
3 months ago
Cassie Elbanay and the FedBiz Access team were exceptional throughout our SAM registration process. Cassie went above and beyond at every step, providing clear guidance that made what can be a complex process feel straightforward. We would absolutely recommend Cassie and FedBiz Access to anyone navigating SAM registrations.
Response from the owner:Our pleasure to be of service year after year. We appreciate your feedback and recognition for the FedBiz Access team and consultant and look forward to continue providing exceptional service and clear guidance.
Thomas Esposito
3 months ago
I had the pleasure of working with Mya, she brought my vision to life and we could not be happier with her work.
Response from the owner:Always a pleasure to be able to bring your vision to life. Thank you for the opportunity to provide marketing and design support for your government contracting needs. Thank you for this five star review for the FedBiz Access team specialist as well.
Tamarah
3 months ago
I had a positive experience working with FedBiz and appreciated the guidance and communication provided during the process. Sidney was responsive and supportive, and I’m grateful for the assistance and encouragement along the way.
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Cami Allen
3 months ago
Ashley was super helpful, professional and timely. The support we receive from FebBiz Access is so helpful in helping us keep current and updated in a sometimes difficult to navigate government world.
Chris Merrill
4 months ago
Cassie and Fedbiz were incredibly helpful, knowledgeable, and responsive throughout the entire process from our initial inquiry through the submission. They made the renewal process easy and fast for us to get through.
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Jeff Lindsey
4 months ago
I've been working with FedBiz Access for years now. Cassie does a wonderful job of making the process easy and quick. She is the best! Thanks, Cassie!!
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Tommy Bohler
5 months ago
Cassie was very helpful throughout the whole renewal process with our municipality and also followed up with assistance on a change in our bank accounts. She was super responsive and took care of our problem almost immediately.
Response from the owner:Our pleasure to provide efficient and valuable guidance as needed. Looking forward to maintaing this level of service at your direction. Thank you for your five star feedback for our team.
John Anderson
5 months ago
Mya did a great job. We completed the capabilities statement in two attempts. On the second attempt, I provided her with some of our pictures, and she embedded them in our statement.
Response from the owner:Our pleasure to assist and create a compelling and appealing visual representation of your govcon capabilities. Thank you for the opportunity to be of service.
Rifles Only
5 months ago
Cassie made renewing our SAMS registration quick and efficient, and maintained great communication with us.
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arnoldo renteria
5 months ago
This team is highly professional and truly knows how to get things done. I am very pleased to have achieved my objective thanks to their support.
Response from the owner:Thank you for your business and this five star google review for the FedBiz Access team; looking forward to continuing working with your objectives and goals for government contracting success.
Harold Quinones
5 months ago
Very easy to work with, knowledgeable, and absolutely handled on your behalf. Recommended.
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George Boza
5 months ago
Mrs. Elbanay continues to be consistently efficient and proficient concerning all all SAM matters. We have worked with her for several years and always go back to her with any SAM or government agency matters. She is pleasant person who listens and resolves any situation and/or subject brought to her attention. Summarizing, she is second to none and we look great forward to working her again.
Once again we have the opportunity to work with Cassie Elbany and as expected she surpassed our expectation with her efficient and professional approach and completion of our new registration. It becuase of Cassie above average support that we work with FEDBIZACCESS and will continue to do so.
Response from the owner:We appreciate the opportunity to continue being of service, as needed, from registration to award. Thank you for your repeat business and your positive feedback for our Fed Biz Access government contracting, dedicated team member.
Julia Perez
5 months ago
SAM Register (Fedbizz Access) has been a great help every step of the way, Thank you Cassie E. for updating me and checking up on the process every step of the way. You have been a great help.
Response from the owner:Our pleasure to assist. Thank you for this five star review for our FedBiz Access dedicated consultant and thank you for your business.
cathy deLeon
6 months ago
Ashley was very helpful as always! Easy to register with FedBiz. Ashley took care of our address cheange fast and efficiently. Thank you!
Response from the owner:Thank you; We appreciate your repeat business and opportunity for FedBiz Access professionals to assist with your government contracting needs.
Meghan Ruth
6 months ago
Cassie has been amazing!!
She is so helpful and such a breeze to work with. I always look forward to talking with her.
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Jessica Sumner
6 months ago
Cassie assisted in making our SAM renewal fast and EASY!!
Response from the owner:Always here to answer any of your government contracting questions and keep the process "fast and easy!". Thank you for your feedback!
Joe Rementer
6 months ago
Cassie was patient and professional in updating my FedBiz account information.
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Warren Gatson
6 months ago
Fedbiz has been the needle in the Haystack! Frank Krebs became Executive Service Contractor's mentor with the information and resources , his professional and friendly approach ESC were awarded a contract with the City of Chapel Hill! Its was a Darn Good Investment!!!
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Shedrick Amin
6 months ago
I recently had the pleasure of working with Fed Bizz Access to renew my SAM.gov registration, and I cannot speak highly enough of the exceptional service I received. From the outset, the process was streamlined, efficient, and handled with the utmost professionalism.
Cassie Elbanay, in particular, was instrumental in guiding me through the renewal process. Her expertise, responsiveness, and attention to detail were evident at every step. She not only addressed my concerns promptly but also crafted a tailored solution that ensured my account was renewed accurately and on time.
What stood out most was Cassie’s proactive approach she anticipated potential issues before they arose and provided clear, actionable guidance that made the entire experience stress-free. Her commitment to client success and her deep understanding of federal registration requirements truly set her apart.
I highly recommend Fed Bizz Access, and especially Cassie Elbanay, to any organization or individual seeking reliable, knowledgeable support with SAM.gov registration or renewal. Their service is a model of excellence in government contracting support.
Response from the owner:We love "Their Service is a model of excellence in government contracting support". Thank you very much for your valued recommendation for the FedBiz Access Team and specialist. We also appreciate your time and effort in leaving us this detailed five star Google review outlining your experience every step of the way, and recognizing the dedication and expertise provided. Our ultimate goal is our client's satisfaction. Thank you.
Jay Reyes
6 months ago
⭐️⭐️⭐️⭐️⭐️ Outstanding Service & World-Class Expertise
Working with Mya Plant at FedBiz has been nothing short of exceptional. From start to finish, Mya demonstrated professionalism, attention to detail, and a true passion for helping small businesses shine.
She crafted a powerful and polished capability statement for my company, Nonstop Delivery & Logistics, capturing our mission, strengths, and federal value proposition perfectly. She didn’t just design a document — she built a brand asset that commands attention and credibility in the government contracting space.
In addition, the company video she produced was absolutely outstanding. It tells our story with clarity, emotion, and professionalism, truly reflecting who we are as a veteran-owned medical logistics provider. The quality, creativity, and messaging exceeded my expectations.
Mya didn’t just deliver — she partnered with us. She listened, guided, and ensured every detail was perfect. Her expertise in federal contracting marketing is unmatched, and I highly recommend her to any business looking to elevate their image and position themselves for government success.
Thank you, Mya — your work plays a crucial role in our continued growth and mission.
Response from the owner:Thank you for the opportunity to be of service; most importantly thank you for your time and effort in posting this five star google review for the FedBiz Access team designer; We are very appreciative of the recognition of the efforts as they are detailed in your review. We aim for attention to detail, exceptional customer service, and an overall client experience mirrored in excellence; we are very happy that your interaction with us reflected exactly that. Thank you for your recommendation as well.
Terrell Scott
6 months ago
Cassie did a very amazing job with would recommend her services
Response from the owner:Looking forward to providing continued service support and success with your government contracting needs. Thank you for this five star google review for the FedBiz Access team and specialist.
Leon Carr
6 months ago
Cassie Elbanay is a consistent and diligent professional when it comes to my business renewal for SAMS!
Response from the owner:Always here to assist you as needed; thank you for your continued support and business with the FedBiz Access team and consultants.
Apar Fones
6 months ago
Ashley Futural was a lot of help finishing the process to get registered. She was very knowledgeable and answered any questions I had.
Response from the owner:Thank you for your loyalty to the FedBiz Access team. Our pleasure to be of service year after year. We appreciate your business and five star feedback for our FedBiz Access team consultant.
LaToya Greene
6 months ago
Ashley Futral is very helpful and knowledgeable. She replies to my emails promptly when I have any questions throughout the year. I appreciate her professionalism and customer service.
Response from the owner:We appreciate the opportunity to be of service and thank you for your valuable feedback. Our pleasue to assist!
Donovan Wright
6 months ago
Very professional and effective service oriented organization and Team guaranteeing the best outcome.
Response from the owner:Congratulatons on your recently awarded certification! Thank you for your service and the opportunity to assist with your government contracting goals!
Debbie Goodin
6 months ago
Ashley Futral is our go-to person for all our Fed Biz needs and questions. We trust her knowledge 100%!
Response from the owner:Thank you for the trust you have placed in us to assist with your government contracting needs and thank you for this five star Google review for our FedBiz trusted consultant.
Heather Kristoffersen
6 months ago
Ashley is amazing. She is always willing to help me walk through the whole process and answer any questions I have along the way!
Response from the owner:Thank you for your business and your time in posting your positive feedback through this five star google review for the FedBiz Access team specialist.
Anthony Padro
6 months ago
Let me tell you — government paperwork is no joke. I went into this SDVOSB certification process fully expecting to lose at least 3 brain cells and my will to live somewhere between page 47 and form 18B. Then came Ashley. Like an angel with a headset, she swooped in and somehow made sense of it all. I swear, this woman could turn a mountain of government forms into a walk in the park.
She’s fast, sharp, and somehow manages to make federal forms almost fun (that’s saying something). Ashley deserves a medal — or at least an unlimited coffee subscription. Thanks to her, my Service-Disabled Veteran-Owned Small Business certification is squared away, and my sanity remains (mostly) intact.
If you’re a veteran business owner trying to navigate this maze, do yourself a favor — call Ashley. She’s a lifesaver with a sense of humor and the patience of a saint.
Response from the owner:its one thing to be enjoying our work; but you've also made reading our reviews extra fun! Thank you for your business but most importantly, thank you for taking the time, energy, and humorous creativity to describe your five star experience with our rockstar FedBiz Access team specialist. Very much appreciated!
Clinton Nguyen
6 months ago
I just wanted to take a moment to express how grateful I am for Cecelia's incredible support throughout the WOSB certification process. Cecelia, at FedBiz, has been absolutely wonderful to work with. Her professionalism, efficiency, and kindness have made a significant difference. She's been instrumental in guiding us through each step, ensuring that we understand and meet all requirements. Cecelia's dedication and hard work have truly made the process smoother and more manageable for us. I can't thank her enough for all the help she has provided.
Response from the owner:Congratulations on your recently awarded WBE/WOSB Government Certification. Thank you for allowing us the opportunity to assist in that process and thank you for your positive and detailed feedback on our team member. We very much appreciate your business and this five star Google review for our FedBiz Access team.
https://i0.wp.com/fedbizaccess.com/wp-content/uploads/2026/03/build-america-buy-america.jpg?fit=1344%2C896&ssl=18961344fedbizadminhttps://fedbizaccess.com/wp-content/uploads/2023/04/fedbizaccess-website-logo.pngfedbizadmin2026-03-18 18:16:302026-03-18 18:17:23Build America, Buy America: The Domestic Content Rule That Can Knock Small Suppliers Out of a Deal Before They Even Know They’re In It
