Has the Government Solicited Bids Under the Correct 2017 NAICS Code? Here’s How to Make Sure That It Does!

On October 1, 2017, the U.S. Small Business Administration (“SBA”) updated its table of the North American Industry Classification System (“NAICS”) codes, which resulted in numerous changes, including additional industries, the merger of industries, and increased and decreased size standards. For example, NAICS 452210 (Department Stores) was combined into one industry from two 2012 NAICS Codes: 452111 (Department Stores except Discount Department Stores) and 452112 (Discount Department Stores). Additionally, NAICS 452210’s size standard increased from 29.5 Million to 32.5 Million. . . . Read More

U.S. Supreme Court Denies Petition for Certiorari on Constitutional Challenge to 8(a) Program

On October 16, 2017, the U.S. Supreme Court denied the petition for a writ of certiorari filed by Rothe Development, Inc. in Rothe Development, Inc. v. Department of Defense & Small Business Administration. Rothe, a non-minority-owned federal contractor, challenged the SBA’s 8(a) Program, a program which gives benefits to small business concerns owned and controlled by socially and economically disadvantaged individuals. Rothe alleged that the statutory basis of the 8(a) Program denies it, a company not owned or controlled by socially . . . Read More

The Weekly Update October 13, 2017

SMALL BUSINESS ADMINISTRATION Women-Owned Small Business Federal Contract Program NAICS Code Updates The U.S. Small Business Administration (“SBA”) has updated the North American Industry Classification System (“NAICS”) codes authorized for use in the Women-Owned Small Business (“WOSB”) Federal Contract Program (“WOSB Program”). The update is being made to reflect the U.S. Office of Management and Budget’s NAICS revision for 2017, identified as NAICS 2017. NAICS 2017 created 21 new industries by reclassifying, combining, or splitting 29 NAICS 2012 industry codes. . . . Read More

Limitations on Subcontracting – What’s the Latest and Why Isn’t It in My Contract Yet?

Over a year ago, SBA released its final rule implementing changes in how limitations on subcontracting are calculated for set-aside prime contracts. Not a day goes by that we do not field  questions  from clients as to what these new SBA regulations mean and how to determine compliance. By far, the biggest query we receive is whether SBA’s limitations on subcontracting rules (e.g., 13 C.F.R. § 125.6) are incorporated into a current contract.   It is SBA’s position that these new . . . Read More

Important Update Regarding 8(a) Applications

Seemingly without notice, this past weekend, SBA updated its General Login System (“GLS”) to no longer allow new 8(a) applicants to create a profile in GLS. This is so that SBA can launch their streamlined and modernized 8(a) application process through certify.sba.gov. The certify.sba.gov platform is SBA’s initiative to harmonize the certification process for all of its small business contracting programs – such as 8(a), woman-owned small business, all small mentor/protégé program, and HUBZone – into one online platform. However, . . . Read More

The Weekly Update September 29, 2017

SMALL BUSINESS ADMINISTRATION “Rules of Practice for Protests and Appeals Regarding Eligibility for Inclusion in the U.S. Department of Veterans Affairs, Center for Verification and Evaluation Database” The U.S. Small Business Administration (“SBA”) is proposing to amend the rules of practice of its Office of Hearings and Appeals (“OHA”) to implement procedures for protests of eligibility for inclusion in the Department of Veterans Affairs Center for Verification and Evaluation (“CVE”) database, and procedures for appeals of denials and cancellations of . . . Read More

SBA Office of Hearings and Appeals Reaffirms “Unconditional Ownership” Requirement in the SBA SDVOSB Program

A recent case reinforces that, just because the corporate governing documents of an SDVOSB  satisfy the unconditional ownership requirements for VA’s  SDVOSB set aside program, does not mean that the unconditional ownership requirements under SBA regulations will be met. Last month, the SBA Office of Hearings and Appeals issued a decision, Veterans Contracting Group, Inc., SBA No. VET-265 (2017), which reaffirmed the SBA SDVOSB Program’s requirement that an SDVOSB be 51-percent unconditionally and directly owned by one or more service-disabled . . . Read More

Do Not Underestimate the Importance of Small Business Subcontracting Plans

Companies that pursue contracts with the Federal Government should not underestimate the importance of small business subcontracting plans. If you do business with the Government and are not a small business, you are likely aware that any contractor receiving a contract with a value greater than $150,000 must agree in the contract that small business, veteran-owned small business, service-disabled veteran-owned small business, HUBZone small business, small disadvantaged business, and women-owned small business concerns will have the maximum practicable opportunity to . . . Read More