Your contract already carries AI obligations.
And a line to fill.
If any part of your scope touches AI — analytics, automation, a model inside a workflow, a vendor tool in a resident-facing system — you have signed clauses that require evidence you may not be resourced to produce. One subcontract can close the compliance exposure and the small-business requirement at the same time.
Can your program produce this today?
Each line below is a clause you have already signed. The question is not whether the obligation applies — it is whether the artifact exists before someone asks for it.
Why an SBE specifically — and why the distinction matters.
35% to small business enterprises
On government-assisted non-construction contracts over $250,000, § 2-218.46(a)(2)(A) requires 35% of dollar volume to go to small business enterprises. CBEs generally are the (a)(2)(B) fallback — available only where qualified SBEs are insufficient. ArcPoint is a certified SBE, which satisfies the primary requirement rather than the exception.
The plan is due before your proposal is accepted
§ 2-218.46(d) makes a bid nonresponsive on a deficient plan — and the plan is due before the District accepts your proposal, not after award. After award: executed subcontract returned for your (h) submission, and quarterly figures for your (i) reports, unprompted.
100% self-performed by the principal
Satisfies § 2-218.46(b-1). Independent advisors are used for surge capacity, never as a conduit. There is no second-tier subcontracting behind this certificate.
Preference does not pass through
§ 2-218.43 preference attaches to the bidder and does not flow through a subcontract. ArcPoint's six designations total 19 points against the 12-point cap — the statutory maximum — which applies where ArcPoint bids as prime or in a certified joint venture under § 2-218.39a. In a standard subcontract your benefit is (a)(2)(A) satisfaction and, at or below $250,000, § 2-218.44 set-aside eligibility.
Subcontract and teaming capability for federal work.
AI governance is arriving in federal scopes faster than programs are staffed for it. ArcPoint teams as a subcontractor against the instruments that already bind the work.
- NIST AI RMF — the methodology baseline, layered with program-specific requirements rather than applied generically.
- OMB M-25-21 and M-25-22 — agency use and acquisition of AI.
- Lifecycle controls — impact assessments, model and system cards, human-oversight procedures, change management, decommissioning.
- AI System IV&V — independent assessment of bias, traceability, and regulatory alignment in high-impact environments.
- OWASP LLM Top 10 — agentic and MCP-connected workflow risk in regulated environments.
- Scope posture: unclassified only — no CUI required, stated plainly up front so the fit question is settled in the first conversation.
Deliverables, not hours.
Proposal-ready governance sections
AI governance narrative written to the solicitation's evaluation criteria, on 48-hour notice, before any subcontract, at no cost. If you don't win, you owe nothing — that is the point.
The clause evidence set
AI Factsheet drafted then maintained annually and on change · values-alignment record per deployment in the form OCTO expects · bias-testing evidence package · incident response procedure · human-accountability procedure with named owners.
CTO approval package
Support assembling the approval package under OCTO IT Procurement Policy §4.2, so the money moves on schedule rather than stalling at a gate nobody staffed for.
A single practitioner is a continuity risk only if the work lives in one head.
Senior-led by the certificate holder means no staffing ramp, no substitution risk, and no second-tier subcontracting. That is the half everyone likes. Here is the other half: the method — intake instrument, evidence request list, scored findings register — keeps work transferable rather than held in one head, and every artifact ships in editable source form.
Committed availability of 40 hours per month per engagement, response within one business day. Fixed fee where scope allows — overrun risk sits with ArcPoint. Teaming is non-exclusive, and never against a partner on the same solicitation.
Quote returned in three business days.
Everything your § 2-218.46(d)(2) plan needs.
| Legal name | ArcPoint Consulting, LLC |
|---|---|
| Address | Washington, DC 20020Full street address on the capability statement, for your subcontracting plan |
| UEI | JE2DLNX4BVQ3 |
| CAGE code | 20CH5 |
| D-U-N-S | 144965471 |
| DC CBE No. | LSDZRE17604082029Valid to August 10, 2029 · LBE · SBE · DBE · DZE · ROB · EIE · verifiable with DSLBD |
| NAICS | 541611 · 541618 · 541690 · 541512 · 611430Small under all listed codes |
| Registrations | SAM.gov active · OCP eSourcing registered |
| Business size | Small Business |
| Scope posture | Unclassified only — no CUI required |
| Point of contact | Jermaine Leonard, AIGP — Founder & Principal Consultant |