It’s time for the SmallGovCon Week in Review. As you head in to your weekend and look forward to Thanksgiving, it’s time to catch up on the latest in federal contracting news. Have a great weekend and enjoy some crisp fall weather.
This week in federal government contracting saw the NDAA rounding into form, changes to space contracting, and updates for how AI can be used in the federal space.
Continue reading…Both the Senate and House, as part of the draft 2026 National Defense Authorization Acts (NDAA), have proposed nearly identical ideas on overhauling the Department of Defense’s Contractor Performance Assessment Report System (CPARS) processes. While both NDAAs have passed, and therefore require reconciliation in a committee, their ideas are extremely similar and signal a coming change in CPARS processes for defense contractors. One big change is to focus on specific negative performance events using “a standardized scoring mechanism” and to remove reporting on “positive or neutral performance assessments.”
Continue reading…Not long ago, we discussed the basics of the Cybersecurity Maturity Model Certification (CMMC) Program at DFARS subpart 204.75. Of course, with such a large new system as the CMMC Program, there is more to it than what we reviewed there. In this second set of posts, we will dive deeper into the requirements and procedures of the CMMC Program implemented by DoD back in September 2025, among other items. We will explore what the general rules on what systems are covered by the CMMC Program, when the contractor must be in compliance with the CMMC Program, and what levels will apply for contracts.
Continue reading…Navigating the U.S. Small Business Administration (SBA) regulations can sometimes feel like navigating through a room filled with laser tripwires. One wrong decision or misstep could result in the company’s disqualification. A company might make a decision relying on its understanding of one SBA regulation, unaware of the application of an entirely different SBA regulation. While a miscalculation in complying with the regulations doesn’t trigger the same disasters shown in an action-packed spy movie, the effects can still be costly.
In Primary Health Care, LLC d/b/a Anglin Distinctive Health Care JV, LLC, SBA No. SIZ-6370 (2025), a joint venture’s misapplication of SBA’s timing rules for size determination standards resulted in the company’s ineligibility for award.
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Happy Friday! It’s been another eventful stretch across the federal landscape, as agencies continue navigating everything from sweeping acquisition updates to the lingering aftershocks of the longest government shutdown on record. In other news, SBA has cleared its VetCert backlog for SDVOSB companies. Check out the articles below for the full rundown and enjoy your weekend!
Continue reading…Long-time SmallGovCon readers are probably aware of the thorny issues presented by an SBA finding of affiliation. When set aside contracts are dependent on a small business size status, an allegation of affiliation with a large business can be a crisis for a small business contractor. SBA’s affiliation doctrine is large and complex (so much so that we have an entire handbook dedicated to the subject). But there is one catch-all affiliation provision that is perhaps the murkiest area of all, meaning the hardest to predict). If SBA does not find affiliation based on things like common ownership or common management (relatively straightforward concepts), it can nonetheless find affiliation based on “the totality of the circumstances.”
A recent OHA decision found affiliation based on totality of the circumstances, in part based on loans causing economic dependence, heavy reliance on infrastructure of an affiliate, and involvement in banking and operations.
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Today, on Veterans Day, we at SmallGovCon take a moment to honor the brave men and women who’ve served our country. We salute those who’ve worn the uniform and their families who’ve stood beside them. Both today and whenever we have the chance.
Because this is a legal blog, we also want to remind you of the federal government’s program for Service-Disabled Veteran-Owned Small Businesses. Those benefits are available to those with disabled status based on their service, and those who work at their companies. It is a program that we hope to see grow even more important in the future.
For our service-disabled veteran readers and our veteran readers, we wish to say thank you. And Happy Veterans Day.