“You’re not the boss of me now” is the chorus of “Boss of Me,” a catchy tune by They Might Be Giants. But when it comes to the SBA size and affiliation rules, there is a boss: the SBA Office of Hearings and Appeals.
Under the SBA size regulations, SBA OHA has the final authority to determine whether a company is small or “other than small” for purposes of a particular procurement. And,as one recent SBA OHA decision demonstrates, if a lower SBA office neglects to follow SBA OHA’s orders, SBA OHA will make sure that the lower office remembers who is the boss.