For better or for worse, these federal procurement “times they are a-changin’.” One obvious source of recent change is the shiny new FAR 2.0, a.k.a. the Revolutionary FAR Overhaul (RFO). With the government’s widespread implementation of the RFO and its many procurement rule and procedure updates, we at SmallGovCon have tried to cover as much as possible. But we’re talking about an essential rewrite of the decades-longstanding procurement playbook here. So unsurprisingly, there’s still a lot to go. One recent change well-worth some deeper discussion is the RFO’s updated “Once 8(a), Always 8(a)” Rule–which I’ve aptly deemed the “Once 8(a), Always 8(a)–or HUBZone, SDVOSB, or WOSB” Rule. As the SBA’s “Once 8(a), Always 8(a)” Rule remains unchanged, this RFO update has the potential for significant impacts on small business federal contracting, as well as some implementation conflicts–or confusion at the least.
Continue readingCategory Archives: 8(a) Program
Posts dealing with the 8(a) business development program, including 8(a) admissions and eligiblity, requests for reconsideration, ongoing eligibility and compliance, and related matters.
A Reversal in Course? SBA Rescinds Several 8(a) Suspension Notices
As you may recall, this past December, SBA launched a massive audit of the 8(a) Program, in which 8(a) participants were required to submit a long list of financial documents for review. Many feared it was the beginning of the end of the 8(a) Program when several 8(a) Participants were hit with suspension notifications earlier this year. Most of these suspensions were a result of SBA’s review of the documents collected during the December data call. The basis was often a claimed failure of these participants to submit all the data asked for. However, as provided for in 13 C.F.R. § 124.305(c), these participants had the opportunity to appeal these suspensions, and many of them took that opportunity. In several cases, it turns out that SBA itself decided that its suspension was unnecessary, and rescinded those actions. Today, we’ll look at this development.
Continue readingWhy File: An Appeal of an 8(a) Program Termination
In a previous blog post, Why File: An Appeal of SBA’s 8(a) Program Denial, we covered the process for appealing SBA’s denial of admission into the 8(a) Business Development Program (AKA 8(a) Program). We discussed what happens when a business is stopped at the door – denied entry altogether in the program. But what happens when a concern already admitted into the 8(a) Program is terminated by SBA? Here, we will touch on the arguably more consequential scenario of an 8(a) Program participant’s termination from the program. Specifically, the termination process, timing considerations, and OHA’s scope of review.
Continue readingBREAKING: SBA’s Newly-Released 8(a) Program Mandate with “Clarifying Guidance” Regarding Social Disadvantage Criteria Brings Far More Confusion Than “Clarity”
On January 22, 2026, SBA issued brand new “SBA Guidance” to its Office of Government Contracting and Business Development and its Office of Field Operations via a highly confusing 8(a) Program Mandate. On its Website, SBA labels it “Clarifying Guidance That Race-Based Discrimination is Not Tolerated in the 8(a) Program[,]” and further labels it the “Latest Action” in our Federal Government’s “Year-Long Effort to Dismantle DEI Discrimination, Expose Fraud, and Restore Fairness in Federal Contracting[.]” But no matter SBA’s intent behind it, this guidance does everything but clarify even a single aspect of SBA’s 8(a) Program eligibility rules and social disadvantage requirement.
Continue readingFive Tips for Surviving the End-of-Year 8(a) Program Audit
If you got an aggressive email from the SBA earlier this month requesting an awful lot of documentation and information in relation to your 8(a) Program participation—you are far from alone. SBA actually sent this December 5th email to about 4300 current and past 8(a) Program participants. And if you too found yourself reading and rereading SBA’s specific requests trying to determine exactly what the SBA is looking for—but to no avail—you are again far from alone. Now, we at SmallGovCon don’t have all the answers or any insider knowledge. But we offer you these five tips for surviving the 8(a) audit—based on our vast experience with the fundamentals of legal language interpretation and our expertise with the 8(a) Program regulations and standard operating procedures.
Continue readingBREAKING: SBA Launches an End of Year 8(a) Program Audit
8(a) Program participants received an early holiday surprise from the SBA’s 8(a) Program this past week. A mass request was sent out to 8(a) Program participants and some graduates requesting extensive (mostly financial) internal documentation so that the SBA could audit the program for any potential fraud, waste, or abuse. While the need to protect taxpayer funds and the 8(a) Program are fundamentally important, such a sudden wide ranging document request came as a surprise to many across federal contracting. The SBA’s explanation provided some insight for this broad request.
Continue reading2025 8(a) Application Updates (Part II): SBA’s 90-Day Final Decision Timeline Delays
Despite various impacts to SBA’s 8(a) Business Development Program–both quite recently and over the last couple years (which you can read about here and here, and even listened to me talk about here)–this “golden child” of SBA’s socioeconomic programs remains alive and well. And it is still one of the most lucrative and sought after SBA certifications out there. So, eligible contractors may be quite happy to hear, even during this most recent government shutdown, the 8(a) application portal remains up and running. In fact, given the current “pause” to other government contracting functions and filing portals, there may never be a better time than right now to work on those 8(a) applications. That said, anecdotally, we at SmallGovCon have been hearing from some 8(a) applicants about recent updates to the 8(a) application process and submission portal that we want to share with our readers via this two part blog. This second installment covers some general (again, anecdotal) application decision timeline updates (and you can read Part 1, about the new application countdown time, here).
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