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White House Announces “Revolutionary FAR Overhaul”: What to Know

Through a duo of Executive Orders (EOs), issued on April 15 and 16 respectively, President Trump announced “a first-of-its-kind overhaul of Federal procurement policy.” The rewrite represents a once-in-a-generation...more

SBA’s OHA Finds Initial Offer To Be Of Consequence, Not Final Proposal Revision, for the “180-Day Rule”

On February 19, the Office of Hearings and Appeals (OHA) denied an appeal from an unsuccessful bidder who argued the awardee was large due to an acquisition that occurred while the award was pending. OHA found that Small...more

New SBA Rule Overhauls Small Business M&A Landscape

On December 17, the Small Business Administration (SBA) published its final rule in response to its August 2024 proposed rule and the ensuing comments from the industry. The rule will have a substantial impact on the...more

Bid Protest Minute: Bidders Beware – Clearly Stated Solicitation Requirements Control

On November 15, the Government Accountability Office (GAO) denied a protest from AtVentures, LLC, a mentor-protégé joint venture, who challenged its exclusion from consideration for award on the basis that it was able to use...more

“Small” Space Companies: Growth Comes at a Cost

Space has become central to protecting U.S. national security interests as Americans increasingly rely on space-based services to support everyday life. As a result, the U.S. government has bolstered investment in the space...more

SBA Seeks to Make Changes to Recertification Requirements for Multiple-Award Contracts

On August 23, the U.S. Small Business Administration (SBA) issued a proposed rule that would make significant changes to SBA’s recertification requirements. Most notably, the rule would change when size and socioeconomic...more

SBICCT Initiative Adds New Tool to Drive Innovation

The Department of Defense (DoD) has long searched for ways to foster innovation in the defense industrial base by harnessing US comparative advantages like our capital markets and American technological innovation...more

OHA Decision Reaffirms SBA’s Strict Adherence to Joint Venture Requirements

In a recent decision, the Office of Hearings and Appeals (OHA) affirmed a Small Business Administration (SBA) Area Office’s size determination and held that procedural deficiencies in a contractor’s Joint Venture Agreement...more

New Guidance Clarifies Facility Clearance Eligibility Determination Requirements for Joint Ventures

On October 5, the Information Security Oversight Office (ISOO) issued a joint notice (Joint Notice) with the Small Business Association (SBA) and in coordination with the Department of Defense (DOD) clarifying that the...more

The Corporate Transparency Act: A Primer for “Small” Businesses

The Corporate Transparency Act (CTA), which aims to curb illicit financial activities like money laundering and other fraudulent activities, will go into effect on January 1, 2024. Consequentially, many types of businesses,...more

UPDATE: 8(a) Reopens its Certify Site Welcoming New Applicants

On September 29, the Small Business Administration (SBA) reopened its Certify portal to new applicants seeking admittance into the SBA 8(a) program....more

SBA Issues Interim Guidance on 8(a) Program Following Ultima Ruling

On July 19, the U.S. District Court for the Eastern District of Tennessee ruled in favor of Ultima Services Corporation, prompting the pause of new 8(a) applications and necessitating a reorganization of the program’s...more

SBA Tidies Up 8(a) Rules in Welcomed Final Rule

Effective May 30, 2023, a Small Business Administration (SBA) final rule made some notable changes to SBA’s 8(a) Business Development (BD) program, a valuable resource for those firms owned by socially and economically...more

Final Rule Makes Host of Changes to SBA Regulations

On April 27, the Small Business Administration (SBA) issued a final rule which, effective May 30, will make a number of changes to the SBA regulations impacting small businesses. The regulations, finalizing the proposed rule...more

SBA Proposed Rule Permits Prime Contractors to Receive Subcontracting Credit from Any Tier

On December 19, 2022, the U.S. Small Business Administration (SBA) issued a proposed rule that would amend the SBA regulations to implement Section 870 of the National Defense Authorization Act (NDAA) of 2020. Section 870...more

Joint Venture Past Performance Can Be Gleaned from Previous Prime-Sub Relationships

Over the last few years, the government has shifted away from lowest price technically acceptable valuations placing a larger importance on past performance. The past performance requirement can sometimes create obstacles for...more

Task Orders May Carry Implicit Size Recertification Requirements

Generally, when a business is awarded a multi-year IDIQ contract, it retains its “small” business designation unless a contracting officer (CO) requires the business to recertify its size status, and has since grown larger...more

Attention SBIR Applicants…Remember that Affiliation Rules Still Apply

The Small Business Innovation Research (SBIR) program has an interesting construction. With seemingly no competition to bring size protests and the successful completion of a previous grant before a second grant, the unusual...more

Proposed Rule for DBE Program Comes as Infrastructure Money Begins to Flow

The Infrastructure Investment and Jobs Act (IIJA) is a historic investment in our nation’s roads, bridges, railways, airports and transportation systems. The bill appropriates $550 billion to physical infrastructure projects,...more

DoD’s Mentor-Protégé Program May Be Getting a Facelift

The Department of Defense’s (DoD) Mentor-Protégé program (MPP) was designed to strengthen the capabilities of small businesses, increase their participation in the DoD contract pool, and contribute to “the diversity and...more

New Certification Process for Veteran-Owned Small Businesses

On July 6, the SBA issued a proposed rule that would implement Section 862 of the National Defense Authorization Act for Fiscal Year 2021 establishing a government-wide certification process for Veteran Owned Small Businesses...more

SBA Enlarges Small Business Pool through New Rule Change

On June 6, the U.S. Small Business Administration (SBA) issued a final rule modifying its methodology for calculating the size of small businesses using an employee-based size standard and authorizes businesses participating...more

COFC: “Rule of Two” Must Be Analyzed Before “Any” Acquisition

The Court of Federal Claims (COFC) recently affirmed that agencies are required to apply the “Rule of Two” to all federal acquisitions in its decision of Tolliver Grp., Inc. v. United States. Further, agencies must give a...more

Size Recertification Prior to Award – When is it Required?

The U.S. Court of Federal Claims (COFC) decision in HWI Gear, Inc. v. United States highlights the importance of reviewing a solicitation to determine if the text of Federal Acquisition Regulation (FAR) 52.219-28 is included...more

Bye Bye 8(a) MPP and Hello to New Small Business Rules!

In October, the U.S. Small Business Administration (SBA) published a final rule entitled “Consolidation of Mentor-Protégé Programs and Other Government Contracting Amendments,” which went into effect on November 16, 2020....more

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