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Office of Hearings and Appeals (OHA)

Bradley Arant Boult Cummings LLP

SBA’s Mass Suspension of 8(a) Contractors Raises Questions About Due Process and Appeal Rights

In a sweeping and unprecedented enforcement action, the Small Business Administration (SBA) has dramatically escalated its oversight of the 8(a) Business Development Program — reportedly leaving more than 1,000 small...more

Clark Hill PLC

SBA Issues Suspension Notices and New Formal Guidance Eliminating Race-Based Presumptions in its 8(a) Business Development Program

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Just two days after the 8(a) BD Program’s Jan. 19, 2026 Data‑Call deadline, the U.S. Small Business Administration (SBA) began issuing Notices of Suspension to over 1,000 of the 4,300 current 8(a) Program Participants that...more

Morrison & Foerster LLP - Government...

Bid Protest Spotlight: Jurisdiction, Contractors, Mentors

This month’s bid protest spotlight features one decision from the U.S. Court of Federal Claims and two decisions from the Small Business Administration’s (SBA) Office of Hearings and Appeals (OHA). In CS 321 East 2nd...more

Bradley Arant Boult Cummings LLP

Understanding the Ostensible Subcontractor Rule: Avoiding Hidden Affiliation Risks in Small Business Contracting

The Small Business Administration’s (SBA) ostensible subcontractor rule remains one of the most consequential — and misunderstood — affiliation principles in federal procurement. For small businesses pursuing set-aside...more

Morrison & Foerster LLP - Government...

Bid Protest Spotlight: Documentation, Overrides, Eligibility

This month’s bid protest roundup highlights three recent decisions that address critical issues for federal contractors: the importance of contemporaneous documentation in proposal evaluations, the standards for overriding a...more

Bass, Berry & Sims PLC

COFC Decision Highlights Risks in Mentor-Protégé Joint Venture Agreements

Bass, Berry & Sims PLC on

On September 18, the Court of Federal Claims (COFC) issued a decision in Multimedia Environmental Compliance Group JV v. United States, denying a bid protest that challenged the Small Business Administration’s (SBA’s) Office...more

Bass, Berry & Sims PLC

Compliance with Limitation on Subcontractor is Ostensible Subcontractor Safe Harbor

On June 2, the Small Business Administration’s (SBA) Office of Hearing and Appeals (OHA) denied a size appeal filed by Veteran Elevator Solutions, LLC (VES) challenging the size of Bass, Berry & Sims’ client GD Resources, LLC...more

Bradley Arant Boult Cummings LLP

SBA OHA: Compliance with Limitations on Subcontracting Can Rebut Ostensible Subcontractor Affiliation

On May 2, 2025, the U.S. Small Business Administration (SBA) Office of Hearings and Appeals (OHA) issued a significant decision in Size Appeal of Bowhead Enterprise, Science, and Technology, LLC, SBA No. SIZ-6352. The...more

Gordon Rees Scully Mansukhani

May 2025 Government Contracts Legal Update and Podcast

Gordon Rees Scully Mansukhani presents the latest insights from our Government Contracts group, offering a comprehensive overview of recent significant decisions, regulatory changes, and essential updates for businesses...more

Morrison & Foerster LLP - Government...

Bid Protest Spotlight: Size, Supply Schedules, SINs

This month’s Law360 Bid Protest Roundup focuses on two Government Accountability Office (“GAO”) decisions and one Office of Hearings and Appeals (“OHA”) decision. From General Services Administration (“GSA”) Schedule holders...more

PilieroMazza PLLC

OHA Confirms Key Affiliation Protections for Tribal Businesses

PilieroMazza PLLC on

On November 15, 2024, the Small Business Administration’s (SBA) Office of Hearings and Appeals (OHA) affirmed the Area Office’s finding that a tribal-owned company was small due to the affiliation exceptions for tribal-owned...more

Holland & Knight LLP

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

Holland & Knight LLP on

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

Venable LLP

SBA Proposes Significant Changes to Size Recertification Rules

Venable LLP on

The Small Business Administration (SBA) has released a proposed rule that would significantly alter a number of SBA small business program regulations, including those governing size recertifications. ...more

Bass, Berry & Sims PLC

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

Bass, Berry & Sims PLC on

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

Morrison & Foerster LLP - Government...

OHA Rules Company Remains Eligible For Award Of Small Business Set-Aside Schedule Orders Even After Acquisition By A Large...

The Small Business Administration (SBA) Office of Hearings and Appeals (OHA) has yet again clarified that a company’s size change in connection with a merger-and-acquisition event generally does not prevent the company from...more

Miles & Stockbridge P.C.

Recent GAO Decision on ‘180-Day Rule’ Underscores Complexity of Regulation

Any acquisition involving a small business government contractor comes with a host of questions concerning what effect, if any, the transaction may have on the small business’s size and status post-closing. ...more

Health Care Compliance Association (HCCA)

CARES Act appeals: Key steps in addressing denials and repayments

With the onset of the COVID-19 pandemic, Congress initiated several programs to help businesses weather the difficult economic conditions. The Coronavirus Aid, Relief, and Economic Security (CARES) Act provided two of these...more

McDermott Will & Schulte

SBA PPP Loan Concerns Linger for Small Businesses

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Many small businesses continue to face uncertainty over whether the Small Business Administration (SBA) will grant forgiveness of their Paycheck Protection Program (PPP) loans. Despite the vast majority of small businesses...more

Morrison & Foerster LLP - Government...

Venture Capital Investment In A Small Business? Know The SBA Rules First.

In recent months, there have been a number of articles about an increase in venture capital interest in entities that do business with the federal government. In fact, this interest is not new. Small entities with venture...more

Cozen O'Connor

Court Ruling Leads to Major Change in SBA 8(a) Social Disadvantage Determination Policy

Cozen O'Connor on

Some significant (perhaps short-term) changes have rapidly come to the U.S. Small Business Administration’s (SBA) 8(a) Business Development Program (8(a) or the Program) following a U.S. Federal District Court for the...more

Holland & Knight LLP

SBA Begins Review of Personal Social Disadvantage Narratives

Holland & Knight LLP on

The 8(a) Program is in a state of uncertainty as the U.S. Small Business Administration (SBA) requires participants who relied on the presumption of social disadvantage to enter the program to obtain SBA approval of personal...more

Venable LLP

Federal Court Potentially Upends Small Business Administration's Method for Calculating Contractors' Annual Receipts in...

Venable LLP on

On May 18, 2023, the U.S. District Court for the District of Columbia (DDC) issued a decision with significant potential consequences for federal contractors and the U.S. Small Business Administration (SBA). ...more

PilieroMazza PLLC

Final Rule Implements New Process for Appealing HUBZone Status Protests

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Based on new rules that take effect on May 10, 2023, the U.S. Small Business Administration (SBA) Office of Hearings and Appeals (OHA) will now hear appeals from Historically Underutilized Business Zone (HUBZone) status...more

Bradley Arant Boult Cummings LLP

HUBZone Appeals Are Coming May 10!

Section 864 of the National Defense Authorization Act for Fiscal Year 2022 authorized the U.S. Small Business Administration’s (SBA) Office of Hearings and Appeals (OHA) to decide all appeals from Historically Underutilized...more

PilieroMazza PLLC

Forming a Joint Venture? SBA Stresses Importance of Complying with State Law

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As PilieroMazza previously highlighted, contractors wishing to pursue set-aside work through small business joint ventures (JVs) must comply with the Small Business Administration’s (SBA) JV regulations, which require certain...more

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