In September 2024, following a temporary application and system pause, SBA switched over to a new, streamlined and unified application portal. Now, applications for the SBA’s 8(a) Program, HUBZone Program, Veteran-Owned Programs, and Woman-Owned Programs all go through MySBACertifications.Gov. Unlike prior portals and procedures, through this one, those eligible have the option to apply for multiple SBA small business contracting programs simultaneously. But the question is, what are the potential risks and benefits of doing so?

As for the application process itself, there are several potential benefits of the simultaneous application submittal option. It is certainly the most efficient way to submit applications to the SBA for participation in multiple socioeconomic programs—given the significant overlap in the required documentation submissions and standard SBA vetting procedures. For example, an applicant’s formation and organizational articles and agreements, copies of licensing and registration forms, tax forms and financial information, and current teaming agreements, subcontracts and other 1099s, joint ventures, mentor-protege agreements, etc., will be required for all of SBA’s socioeconomic programs.

Additionally, for those SBA socioeconomic programs with similar ownership and control requirements (i.e., WOSB/EDWOSB, SDVOSB/VOSB, and 8(a) Program), SBA requires similar documentation and information demonstrating the qualifying individual’s/individuals’ direct ownership and unconditional control of the applicant’s day-to-day and long-term business operations. SBA will also require information on and documentation from any additional owners for all of these programs’ applications. As part of SBA’s control analysis for all such programs, it will also almost always require further information and/or documentation regarding any spouse involved in the applicant’s business, as well as any officers, board members, and employees holding critical licenses. And that is just one of the many reasons SBA nearly always comes back to an applicant, after the initial application package is submitted for any of SBA’s socioeconomic programs, asking follow-up questions and requesting further information and documentation–prior to deeming any such application “complete” and making a final decision on certification.

So, its easy to see the benefits of submitting all of the necessary documentation, providing all of the required information, answering all of SBA’s follow-up questions, and meeting all of SBA’s follow-up requests for all the socioeconomic programs an applicant is seeking certification in–all at once. Such is clearly the most efficient use of the applicant’s time and resources.

But recently, we’ve discovered anecdotally that simultaneous application specifically to SBA’s 8(a) Program and to any, some, or all of SBA’s other socioeconomic programs may not be the best option–at least not for any applicant hoping to achieve certification in any of the latter SBA socioeconomic programs in a timely manner. Indeed, SBA has openly acknowledged “ongoing delays with 8(a) processing,” which have already blogged about here–and which can likely at least in part be traced back to recent 8(a) audits and investigations we’ve blogged about here and here.

As a result of these 8(a) application-specific processing delays, multi-program eligible applicants may now want to seriously consider applying for all other desired SBA socioeconomic programs first and awaiting SBA’s decision(s) there before proceeding with 8(a) Program application. Anecdotally, SBA has suggested that certification for other socioeconomic programs could take far less time than 8(a) Program certification–at least for the time being–potentially looking at a matter of weeks for WOSB/EDWOSB and/or VOSB/SDVOSB processing versus a matter of several months for 8(a) processing.

Again anecdotally, SBA has even offered applicants with multiple pending socioeconomic certifications the option to withdraw their 8(a) applications to allow their WOSB/EDWOSB and/or VOSB/SDVOSB applications to process in a much more timely manner. But in such scenarios, SBA has also cautioned that a full 8(a) reapplication would still be required once the other certifications are granted–meaning having to again upload all documents, answer all questions, provide all information, and undergo SBA’s vetting process all over again.

For those multi-program-eligible applicants seeking 8(a) status above all others, it seems the best advice is likely still to get that 8(a) application in and completed as soon as possible. But for those multi-program-eligible applicants seeking 8(a) that also have plenty of other socioeconomic program opportunities on their radar, it seems waiting to submit for 8(a) until after SBA grants certification in the other socioeconomic programs may well be worth some thought.

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