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The Post-IEEPA Landscape: Practical Guidance for Government Contractors

For government contractors, the stakes are especially high. Many contractors either absorbed IEEPA‑driven cost increases or passed them through to the government and other customers under existing contract mechanisms. As...more

DOW Announces Review of All Small Business Set-Aside Contracts Over $20 Million

U.S. Department of War (DOW) Secretary Pete Hegseth on January 16, 2026, posted a video on social media calling for a line-by-line review of DOW 8(a) sole-source contracts of more than $20 million. The secretary stated his...more

SBA Issues Formal Guidance Regarding the 8(a) Program

The U.S. Small Business Administration (SBA) on January 22, 2026, issued a press release and formal guidance related to the 8(a) Business Development Program (8(a) Program). The 8(a) Program provides federal government...more

Defense Contractors Face New Scrutiny Under the Trump Administration

The White House on January 7, 2026, issued an executive order (EO) titled "Prioritizing the Warfighter in Defense Contracting," which aims to accelerate defense procurement and enhance the defense industrial base by shifting...more

A New Era for Small Business: Key Takeaways from the FAR Part 19 Rewrite

As part of its Revolutionary FAR Overhaul (RFO), the Federal Acquisition Regulation Council (FAR Council) on Sept. 26, 2025, issued its long-awaited update to FAR Part 19, which governs the small business program. FAR Part 19...more

Executive Orders Issued to Overhaul FAR, Direct Procurement of Commercial Products and Services

President Donald Trump issued an executive order on federal procurement titled "Restoring Common Sense to Federal Procurement" on April 15, 2025 (the April 15 EO), directing that the Federal Acquisition Regulation (FAR) be...more

What to Do in the Event of Federal Procurement Disruptions

The Trump Administration is in the midst of reviewing prior administrations' spending priorities and federal government contracts and has begun announcing a variety of actions to suspend and/or terminate pending and awarded...more

SBA's New Rule Clarifies Role of Minority Equity Holders in Small Businesses and 8(a) Concerns

The U.S. Small Business Administration's (SBA) Final Rule, which takes effect on Jan. 16, 2025, makes a range of substantive changes to the regulatory regime for small business contractors. Holland & Knight previously...more

The Storm Before the Calm: SBA Final Rule Delays Impact of Future Post-M&A Recertifications

The U.S. Small Business Administration (SBA) on Dec. 17, 2024, issued a Final Rule that substantially changes the effect of recertifications of size and socioeconomic status under set-aside contracts following the merger or...more

SBA Proposed Rule Seeks to Expand "Rule of Two" to Multiple Award Contract Task Orders

The U.S. Small Business Administration (SBA) on Oct. 25, 2024, issued a proposed rule aimed at increasing small business participation in multiple award contracts (MACs) by expanding the application of the Rule of Two to...more

How SBA's Proposed Size, Status Recertifications Rule Could Impact Small Business M&A

The U.S. Small Business Administration (SBA) on Aug. 23, 2024, issued a Proposed Rule that significantly changes the effect of recertifications of size and socioeconomic status under set-aside contracts following a merger or...more

The (Uncertain) Application of the Corporate Transparency Act to Tribal Entities

The Financial Crimes Enforcement Network (FinCEN), a unit of the U.S. Department of the Treasury (Treasury Department) charged with administering the Corporate Transparency Act (the CTA), on Aug. 1, 2024, held a Tribal...more

SBA Notices Tribal Consultation in Advance of Proposed Rule Affecting HUBZone, 8(a) and Other Small Business Contracting Programs

On July 22, 2024, the U.S. Small Business Administration (SBA) published a Notice of Tribal Consultations (Notice) in the Federal Register related to a forthcoming proposed rulemaking affecting a number of SBA's small...more

SBA, DoD-NISP Release Notice on Security Clearance Requirements for Joint Ventures

The Information Security Oversight Office (ISOO) released a joint notice on Oct. 5, 2023, providing clarifying guidance to agencies on facility security clearances for joint ventures in the National Industrial Security...more

SBA Issues More Guidance on Use of 8(a) Program During Ultima Injunction

The U.S. Small Business Administration (SBA) continues to navigate the impact of the injunction entered in Ultima Servs. Corp. v. U.S. Dep't of Agric., No. 2:20-CV-00041-DCLC-CRW, 2023 WL 463348 (E.D. Tenn. July 19, 2023)...more

SBA Extends Moratorium on Bona Fide Office Requirements for 8(a) Construction Contracts

The U.S. Small Business Administration (SBA) announced on Aug. 21, 2023, that it was extending its moratorium on the application of the "bona fide office" requirements for construction contracts under its 8(a) Business...more

SBA Releases Interim Guidance on 8(a) Program in Light of Ultima Decision

As announced by U.S. Small Business Administration (SBA) Associate General Counsel for Procurement Law John Klein in an Aug. 17, 2023, webinar, SBA has issued a press release and interim guidance regarding its implementation...more

District Court Enjoins SBA from Using Race-Based Rebuttable Presumption Under 8(a) Program

The U.S. District Court for the Eastern District of Tennessee ruled on July 19, 2023, in Ultima Servs. Corp. v. U.S. Dep't of Agric. that the U.S. Small Business Administration's (SBA) and U.S. Department of Agriculture's...more

SBA Issues Final Rule on Ownership and Control Changes for the 8(a) Program

The U.S. Small Business Administration (SBA) issued its final rule on April 27, 2023, implementing several changes to the ownership and control requirements for the 8(a) Business Development program. The final rule also...more

What Hitting the Debt Ceiling Might Mean for Federal Contractors

The United States is likely just weeks away from the federal government reaching the maximum debt ceiling. The U.S. Department of the Treasury is not permitted to expend funds beyond the current debt limit (because it has no...more

GAO: Bid Protest Activity Fell Again, But Protester "Effectiveness Rate" Increased

The U.S. Government Accountability Office (GAO) issued its annual Bid Protest Report to Congress for Fiscal Year 2022 on Nov. 1, 2022. The annual report is a requirement of the Competition in Contracting Act and an...more

SBA Adopts 24-Month Lookback for Employee-Based Size Standards

The U.S. Small Business Administration (SBA) issued a final rule on June 6, 2022, making significant changes to its methodology for calculating the size of certain businesses. The rule becomes effective July 6, 2022....more

Indian Health Service Releases Final Rule on Buy Indian Act

The Indian Health Service (IHS), an agency within the U.S. Department of Health and Human Services (HHS), published its Final Rule governing implementation of the Buy Indian Act (87 FR 2067) on Jan. 13, 2022. These Buy Indian...more

DHS Soliciting Small and 8(a) Business Capabilities for $181 Million Cybersecurity Contract

The U.S. Citizenship and Immigration Services (USCIS), a component of the U.S. Department of Homeland Security (DHS), has issued a request for information (RFI) seeking information from industry, and in particular small and...more

GAO Clarifies Stance on Joint Ventures and Facility Clearances

In a bid protest decision released on Aug. 27, 2021, the Government Accountability Office (GAO) has resolved a long-simmering question regarding joint ventures and facility clearances. Specifically, in InfoPoint, LLC,...more

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