SBA Proposed Rule: SBA Plans to Relax 8(a) Program Restrictions

The SBA recently dropped a large proposed rule that it grouped mainly under the HUBZone program, but actually touches on almost every SBA socioeconomic certification. So, it should come as no surprise that the SBA’s 8(a) Program is facing some potential changes based on this proposed rule. There are quite a few proposed updates to the 8(a) Program. We wanted cover just a few that really stood out to us here at SmallGovCon. Be sure to review the whole rule if you want to comment on any of these 8(a) changes.

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SBA Getting Strict on MPA Language

One of the most popular programs in small business federal contracting seems to be the SBA’s Mentor-Protege Program. It is generally a great program for small businesses to utilize the resources and knowledge of a larger or more experienced business to grow. In turn, it also gives large businesses the ability to work on small business contracting opportunities, and the Government the ability to contract with more robust teams. Unfortunately, there has been a recent trend of the SBA being somewhat strict on minor language in Mentor-Protege Agreements, possibly stifling participation in the program, or at least making it take longer for SBA to approve these agreements.

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GAO Reminder: Joint Ventures Must Register on SAM

SAM.gov is like the home base of federal government contracting. Everything in federal government contracting seems to either start there, or require using SAM in some fashion. As a consequence, contractors are expected to register on SAM to work in federal contracting. However, it can be easy to overlook registering a joint venture entity on SAM, when contractors making up the joint venture are already registered on SAM. GAO recently took the opportunity to remind contractors of the need to register their joint venture separately on SAM through a bid protest decision.

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SBA Certify Portal Applications to be Paused

If you have ever looked into socio-economic certifications through the SBA or “set-asides” as some call them, you undoubtedly have run into SBA’s certify portal. It certainly is a big part of the small business federal contracting landscape, with likely massive numbers of site visitors a day. However, it will soon be updated, causing a pause on new applications very soon.

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SBA Confirms GSA Schedule-Holders Who Outgrow Size Standard Can Still Get Awarded Set-Aside TOs and Options

Many contractors utilize a GSA schedule contract to provide the Government with their products and/or services. After all the effort it takes to get on a GSA schedule contract, a contractor would certainly not want to lose its chance at a small business task orders issued under it, just because it’s circumstances have changed since it first got the schedule contract as a small business. In a recent decision, the SBA’s Office of Hearings and Appeals (“OHA”) confirmed that even if a business changes size after being awarded a GSA schedule contract, it can still compete for small business task orders from a Blanket Purchase Agreement (“BPA”) awarded under it.

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Back to Basics: Agency Contracting Authority

So much of federal contracting discussion is focused on the pursuit of contracts (set-aside certifications, size status, solicitation terms, bid protests etc.). But, what sometimes gets lost in all of that is what happens after. The performance of a contract is where the rubber meets the road in federal contracting, but that doesn’t mean agencies are without limits on what they can do during performance.

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Even Rules have their Limits, Says SBA OHA about the Nonmanufacturer Rule

In a recent size appeal, the SBA OHA made it clear that the nonmanufacturer rule has it limits, and will not apply depending on the dollar value of the acquisition. OHA reminded contractors that the nonmanufacturer rule applies only to acquisitions over the simplified acquisition threshold.

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