SBA OIG Issues Warnings on Limitations on Subcontracting

The Small Business Administration (SBA) Office of Inspector General (OIG) has a mission to “provide independent, objective, and timely oversight to improve the integrity, accountability, and performance of SBA and its programs.” As part of this mission, it investigated and recently issued a report on the federal government’s “oversight work to identify opportunities to strengthen federal-wide compliance with limitations on subcontracting requirements for set-aside awards.” The SBA’s rules on limitations on subcontracting limit how much of a federal contract a small business prime contractor can subcontract to subcontractors that are not similarly situated. OIG identified a number of areas where federal agencies could improve their oversight of small business subcontracting, noting “recurring deficiencies in the federal contracting community’s ability to interpret the rule’s requirements, apply them consistently, and monitor and enforce compliance throughout the life of a contract.” SBA has indicated it will issue a revised rule to address some of these concerns. Let’s take a look.

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Come with a Plan, Says SBA OIG in Review of SBA Mentor-Protege Program

Way back in 2019, the SBA’s Office of Inspector General (OIG) issued a report on the SBA’s (then named) All Small Mentor Protege Program. At that time the SBA OIG found that the SBA didn’t create effective controls to ensure mentor-protege application reviews and evaluations were made in accordance with the regulations and SBA did not make sure such reviews and evaluations measured program success. The SBA OIG gave the SBA a list of recommendations at that time to fix those issues. At the end of September 2026 (after giving SBA a seven-year window), the SBA OIG revisited its 2019 inspection of the SBA’s Mentor-Protege Program (MPP) and found there were some improvements, but still some issues with the MPP, especially regarding protege business plans.

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2025 GAO Bid Protest Report: Numbers Down, Effectiveness Still Even Odds–COFC Shows Increase in Bid Protests

In just a few days the ball will drop on 2025 and we will officially usher in the new year. It’s always a good time for reflecting on the past year and what lies ahead for the new year. And that same sort of review is important when thinking about federal contract bid protests. With that in mind, we are going to take a look at the GAO’s Bid Protest Annual Report. This report is GAO’s summary of bid protests for the previous fiscal year. It contains some important insights for how GAO bid protest numbers have changed from prior years. But as our readers know, many bid protests are filed at the Court of Federal Claims, so this is only one part of the overall bid protest picture.

Here are some key points from this year:

  • The key effectiveness metric, showing numbers of sustains and corrective actions at GAO, was similar to prior years, and exactly the same as 2024, at 52% for the 2025 fiscal year.
  • Total bid protest numbers were down for the second year in a row, coming in at 1688 new cases filed (a 6% decrease from the prior fiscal year).

Below, we dive into the GAO numbers while comparing to the data we have on COFC protests.

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FY2024 Small Business Scorecard Shows Strong Small Business Federal Contracting Numbers

Once a year the SBA publishes its scorecard which rates how well federal agencies have met their small business contracting goals. The purpose? To provide a sense of how strong the federal government’s small business contracting initiatives are performing on an annual basis. And for 2024, the overall federal contracting dollars paid to small businesses looked good. However, the agency-specific numbers were not consistently as promising for small businesses.

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Small Business Contracting Goals: Current State of Agency Goals

In recent years, the Small Business Administration’s small business contracting goals have been on an upswing, with the requirements growing beyond the statutorily required minimums in an effort to encourage federal agencies to increase awards to small businesses, especially disadvantaged businesses. That is, until now. With the current administration’s focus on “Ending Radical And Wasteful Government DEI Programs and Preferencing,” or Executive Order 14151, there has been a sharp decrease to the small disadvantaged business contracting goals set for federal agencies, but an increase to many of the agencies’ overall small business contracting goals. Read on to learn more about these changes, as well as some potential impacts of the new small business contracting goals.

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2024 GAO Bid Protest Report: Numbers Down, Effectiveness Still Even Odds

As we look forward to fall traditions like turkey and mashed potatoes, pumpkin spice, and leaf peeping, don’t sleep on another fall tradition, the GAO bid protest report. This report is GAO’s summary of bid protests for the previous fiscal year. It contains some important insights for how GAO bid protest numbers have changed from prior years. Of course, many bid protests are filed at the Court of Federal Claims, so this is only one part of the picture.

Here are some key points from this year: (1) the key effectiveness metric, showing numbers of sustains and corrective actions at GAO, was similar to prior years at 52% for the 2024 fiscal year and (2) total bid protest numbers were down slightly from 2023 but a little above the number for 2022. Numbers are still lower than in 2021 and 2020.

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GSA Report: Be Truthful about Small Business Certifications

The federal small business representation system relies in some part on self-certification and in some part on review by the Small Business Administration (SBA) and protests by competitors. The System for Award Management (SAM) is one key part of the federal procurement apparatus. Small businesses looking to take advantage of SBA’s socioeconomic programs must be registered in SAM, and crucially, must maintain up-to-date information in the system. Failure to do so can carry severe consequences, ranging from suspension and disbarment to civil and/or criminal penalties, including massive fines and even imprisonment. We’ve written before about some of the confusion contractors may have regarding self-reporting in SAM.

A recent General Services Administration (GSA) Office of Inspector General (OIG) report is a reminder to federal contractors about the importance of being accurate in representing small business status. It details several investigations into small business misrepresentations, and reminds contractors of the severe penalties that can result from misrepresentation. In this post we’ll highlight the examples provided by GSA OIG to show just what is at stake when a small business fails to update (or knowingly misrepresents) their status, and offer some clarification of the Federal Acquisition Regulations to help you avoid similarly extreme penalties.

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