Counting the Hours: SBA Adding More MPA Requirements

The SBA’s Mentor-Protege Program (MPP) continues to be one of the most popular programs at the SBA. The MPP is a great way for federal contractors to grow and learn from more experienced contractors, in a way that is shielded from size affiliation risks. Historically, the Mentor-Protege Agreement (MPA) between a mentor and protege was a flexible document that allowed the parties to make sure their participation in the program truly fit their processes and aims in their own words. However, in recent years the SBA’s MPA reviews have seemingly taken stricter stances on the format and content of the MPA, leading to confusion among contractors on what they are supposed to draft in their MPA. Recently, we have become aware of the SBA implementing more requirements on MPAs that contractors are not warned about prior to applying to the MPP.

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SmallGovCon Week in Review: July 27-31, 2026

Happy Friday! It’s been another busy week in the federal government contracting arena. I’m filling in for Shane McCall for the Week in Review, while Shane and his family enjoy a well-deserved vacation away from the humidity and heat we have been experiencing here in the midwest. July feels like it has come and gone quite fast. All of us here at SmallGovCon hope our readers have enjoyed this past month celebrating the 250th anniversary of our country with family and friends, and that you all have a relaxing weekend.

For small businesses in the GovCon space, this week was a reminder that staying informed is just as important as staying compliant. Lawmakers continue to debate procurement reforms, while agencies are emphasizing stronger supply chain security and reviewing cybersecurity requirements that directly affect small contractors. With changes to acquisition policies and ongoing discussions around small business programs, now is a great time to review your certifications, strengthen your compliance posture, and keep an eye on upcoming opportunities.

Below are a few articles from this week’s news in federal government contracting. Enjoy the weekend!

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SAM Registration: Defining “Immediate Owner” and “Highest-Level Owner”

SAM.gov is something every federal government contractor has to deal with for actions like searching solicitations and registering to be a federal contractor. As every federal contractor wanting to do business with the federal government has to register on SAM, the questionnaires on SAM must cover a wide array of different possible businesses and business structures. As much as SAM tries to make sure to cover all the possibilities, inevitably, there are some questions that could have so many answers that contractors will often have their own questions about how to answer them properly. One of the most common questions that come up from contractors during SAM registration is “what do I put for Immediate Owner on SAM?” or “what does Highest-Level Owner mean?”

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GAO Sustains Protest Due to Agency’s Inadequate Documentation and Unequal Evaluation of Offerors 

As regular SmallGovCon readers surely know, federal agencies have a great deal of discretion when procuring products and services. Protesters are often facing an uphill battle in attempting to demonstrate an agency abused that discretion in making an award. This is because typically, so long as the agency properly documents its decision making process, sticks to the solicitation terms, and there is documentation in the record that reasonably supports the agency’s decision, GAO will rule in the agency’s favor. Nevertheless, there are occasions when the agency will apply evaluation criteria unevenly, or base its decision on facts or considerations that are not allowed under the Solicitation. This is precisely what happened in a recent GAO protest which resulted in a win for the protester, and serves as a great reminder for contractors as to what situations may result in a successful bid protest.

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GAO Recommends Practicing Mindfulness When Solicitation Terms Cover Multiple Evaluation Factors

Even if we don’t want to admit it, we all simply click “accept” on all those different terms and conditions for software, despite not actually reading the actual terms. GAO in a recent decision reminded agencies and contractors to not let that habit happen when you read the terms of a procurement. In that recent GAO decision, there was a long history of protests, which resulted in an amendment to the solicitation. At first glance, the amendment and proposal revision restrictions tied to it may have made sense, but upon protest, GAO found the limitations on proposal revisions were improper, due to the amendment impacting more than the one factor which was open for revisions.

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Back to Basics: Price Realism vs. Price Reasonableness

As part of federal contracting, the total price of each award is disclosed. This is of course a great way to promote trust and transparency in federal contracting and in the handling of taxpayer dollars. But it also leads to other contractors scrutinizing an awardee’s price and thinking one of two things: (1) “That price is too low to do this work”; or (2) “that price is too high for this work.” Naturally contractors will consider protesting on one of those pricing intuitions, but often mix up how to properly frame or phrase that pricing concern. Thus, they find themselves at the crossroad of “price realism” vs. “price reasonableness.” This installment of our Back to Basics series will help you learn which is which and why that matters.

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OMB Continues Push for Commercial Products and Services

In Spring 2025, President Trump issued Executive Order 14271, titled “Ensuring Commercial, Cost-Effective Solutions for Federal Contracts” which informed agencies that they should emphasize procuring commercially available products and services as much as possible. Fast forward a year later, and it would seem the White House’s Office of Management and Budget (“OMB”) is not seeing the push for utilizing commercially available products and services they expected among federal agencies. So a few weeks ago, almost a year to the day of President Trumps 2025 Executive Order, OMB issued a memo to federal agencies driving home the points of President Trump’s 2025 Executive Order and placing reporting requirements on agencies, which could effect the direction of future possible procurements across federal contracting.

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