SBA Proposes to Eliminate Some 8(a) Joint Venture Agreement Approval Requirements

Recently, the SBA proposed big changes for its small business regulations, including some aspects of the 8(a) Program.

This post is Part 4 in our coverage of these proposed SBA changes and will cover the SBA’s potential changes to the joint venture agreement approval process for 8(a) contracts (here are part 1, part 2, and part 3 of our coverage).

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Joint Venture Facility Security Clearances: SBA Wants Feedback

Forming a joint venture is an important tool to help small businesses increase their competitiveness under federal acquisitions. But for all the benefits, some headaches remain.

One common issue arises when a solicitation requires the prime contractor to hold a facility security clearance. Because a joint venture is an unpopulated legal entity formed for the purpose of bidding on a specific opportunity, the joint venture itself (as the prime contractor) often lacks the needed clearance—even though the joint venture’s members might both hold it. In these situations, a form-over-substance evaluation may leave the joint venture ineligible for award.

Fortunately, the SBA has recognized the silliness of such an exclusion and has invited feedback on a potential solution.

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SBA Proposes Changes to Nonmanufacturer Rule and Limitations on Subcontracting

The SBA recently proposed regulatory changes for a number of small business rules. While my colleagues have addressed some of the other big changes, I’ll focus on changes to the nonmanufacturer rule and limitations on subcontracting. The SBA noted that these changes are meant to eliminate confusion and streamline both processes.

Keep reading to see if you agree.

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SBA Proposes Changes to 8(a) Contract Procurement Process

Last week, SBA proposed big changes for some of its small business regulations, particularly those in the 8(a) Program. This blog post is Part 2 in our coverage of the proposed amendments (see Part 1 here) and will cover SBA’s potential changes to the procurement process for 8(a) contracts.

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GAO Recommends Improvements For Comments on Proposed Federal Agency Rules

Have you ever felt like you were screaming into the void when submitting your comments to a proposed rule in the Federal Register? That your well thought out comments were being drowned out by a mass of other comments on a proposed rule or attributed to someone else? Have you wondered what agencies do with all that information you send them when you submit a comment on a proposed rule?

Well, GAO seems to have the same questions and concerns regarding the proposed rule comments process and has taken time these past few months to examine how agencies wade through comments on proposed rules, publish them, and clearly attribute identities to them.

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Alert! SBA Proposes to Consolidate the All-Small and 8(a) Mentor/Protégé Programs

As many small business government contractors know, the SBA offers two mentor/protege programs: one reserved for 8(a) participants; the other, a universal program open to all small businesses—not just 8(a) companies.

Since the All-Small Mentor/Protege Program was rolled out in 2016, many have wondered why the SBA still runs two programs, instead of a single, consolidated program.

Fans of government efficiency, your cries are soon to be answered. Earlier today, the SBA issued a comprehensive proposed rule that, among other things, would consolidate the 8(a) Mentor/Protégé Program into the All-Small Mentor/Protégé Program.

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