One of the most overlooked compliance requirements for set-aside contracts are the limitations on subcontracting. Don’t take my word for it—GAO has noted in several reports that contracting officers generally do not monitor or enforce the requirement that the small business prime contractor must self-perform a certain percentage of the contract. The limitations on subcontracting requirements are critical to the efficacy of the small business programs. Indeed, the goals of the programs are not served if small businesses do not perform contracts reserved explicitly for them. As new SBA rules have taken effect on December 30th, we expect enforcement to be a more significant focus in 2020. As a result, government contractors large and small need to make a New Year’s resolution to adjust or implement compliance strategies to ensure they understand and satisfy the limitations on subcontracting for set-aside projects.
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