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2023 Procurement Review--Statutes, Regulations, Executive Orders



Contents

                           

    Statutes       

Executive Orders and Related Publications

Regulations

Federal Acquisition Regulation (FAR)

Federal Acquisition Circulars (FAC)  

FAC 2023-02

Federal Acquisition Circular (FAC) 2023-02 included the following two items plus technical amendments: 

FAR Case 2020-007: A final rule amended the FAR by implementing section 873 of the NDAA for FY 2020, which provides for accelerated payments to contractors that are small businesses and to small business subcontractors by accelerating payments to their prime contractors.

FAR Case 2019-008: A final rule amended the FAR to conform the FAR to changes the SBA  made to its regulations in its final rule published on November 29, 2019, which implemented several provisions of the NDAAs for FY 2016 and 2017 and the Recovery Improvements for Small Entities After Disaster Act of 2015 (RISE Act) and also clarified existing regulations.

The technical amendments can be found here.

FAC 2023-03

FAC 2023-03 included the following items:

FAR Case 2022-007: A final rule amended the FAR to implement the statutory expiration of the Federal Helium System in accordance with the Helium Stewardship Act of 2013.

FAR Case 2022-002: A final rule amended the FAR in accordance with section 861 of the NDAA for FY 2022, which provides for a statutory exception to the periodic inflation adjustments of acquisition-related thresholds for certain bond requirements under 41 U.S.C. 1908.

FAC 2023-04

FAC 2023-04 included the following item:

FAR Case 2023-010: An interim rule amended the FAR to implement section 102 of Division R of the Consolidated Appropriations Act of 2023 (the "No TikTok on Government Devices Act") and its implementing guidance under OMB Memorandum M–23–13 by adding FAR clause 52.204–27 ("Prohibition on a ByteDance Covered Application"). The rule and the clause ban the presence or use of TikTok  on any information technology owned or managed by the Government or on any information technology used or provided by the contractor under a contract, including equipment provided by the contractor’s employees, unless an exception is granted in accordance with OMB Memorandum M–23–13. 

FAC 2023-05  

FAC 2023-05 included the following three items.

FAR Case 2017-014: A final rule amended the FAR to encourage use of voluntary feedback mechanisms, where appropriate, to support continual improvement of the acquisition process.

FAR Case 2023-004: A final rule amended the FAR, inter alia,  to implement regulatory changes made by the SBA in its interim rule published on November 17, 2022 (at 87 FR 69118), which adjusted for inflation the net worth threshold for an individual to be eligible as an owner of a small disadvantaged business concern from $750,000 to $850,000. To do so, this rule updates this threshold to reflect a reference to SBA’s regulations at 13 CFR 124.104(c)(2), which is used in the definition of "small disadvantaged business concern," in the FAR.

FAR Case 2022-008: A final rule amended the FAR to update the contact information, web addresses, and office titles necessary to obtain federal and Defense specifications and standards from the DoD Acquisition Streamlining and Standardization Information System (ASSIST) website or, for Defense documents not available in ASSIST, the Defense Standardization Program Office. This final rule also adds a reference in part 53, Forms, to the American National Standards Institute (ANSI) Z39.18, Scientific and Technical Reports—Preparation, Presentation, and Preservation, with the prescription for the Standard Form 298, Report Documentation Page.  

FAC 2023-06

FAC 2023-06 included the following three items:

FAR Case 2020-011: Effective December 4, an interim rule amends the FAR to implement supply chain risk information sharing and exclusion or removal orders consistent with the Federal Acquisition Supply Chain Security Act of 2018 and a final rule issued by the Federal Acquisition Security Council. Comments are due by December 4.

FAR Case 2017-005: A final rule amended the FAR to implement Pub. L. 114–261 to enhance whistleblower protection for contractor employees. The rule makes permanent the protection for disclosure of certain information. It also clarifies that the prohibition on reimbursement for legal fees accrued in defense against reprisal claims applies to subcontractors, as well as contractors.

FAR Case  2021-012: A final rule amended the FAR to implement regulatory changes made by the SBA in its final rule published in the Federal Register at 85 FR 66146 on October 16, 2020 to more clearly articulate the SBA’s intent with regard to certain aspects of the 8(a) program and to eliminate confusion and decrease burdens on procuring activities and 8(a) participants. 

FAC 2024-01

FAC 2024-01 included the following item:

FAR 2023-019: A final rule amended the FAR to add North Macedonia as a new designated country under the World Trade Organization Government Procurement Agreement.

FAC 2024-02

FAC 2024-02 included the following item:

FAR Case 2022-003: Effective January 22, 2024, a final rule amends the FAR to implement E.O. 14063 ("Use of Project Labor Agreements for Federal Construction Projects"), which mandates that federal government agencies require the use of project labor agreements (PLAs) for large-scale federal construction projects, where the total estimated cost to the Government is $35 million or more, unless an exception applies. Agencies still have the discretion to require PLAs for federal construction projects that do not meet the $35 million threshold. The E.O. also directs the OMB to issue implementation guidance to agencies on exceptions and reporting.  

Other Proposed FAR Revisions

FAR Case 2018-003: Because of a change in the underlying statute, a proposed rule concerning credit for lower tier small business subcontracting was withdrawn.

FAR Case 2022-006: A proposed rule would amend the FAR to restructure and update the regulations to focus on current environmental and sustainability matters and to implement a requirement for agencies to procure sustainable products and services to the maximum extent practicable.

FAR Case 2020-005: A proposed rule would amend the FAR to implement section 874 of the NDAA for FY 2020, which, for task orders or delivery orders exceeding the simplified acquisition threshold but not greater than $6 million, requires contracting officers to provide, upon written request from an unsuccessful offeror (aka unsuccessful awardee), a brief explanation as to why the offeror was unsuccessful, including the rationale for award and an evaluation of the significant weak or deficient factors in the offeror’s offer.

FAR Case 2020-016: A proposed rule would amend the FAR to implement regulatory changes made by the SBA in its final rule published on October 16, 2020, at 85 FR 66146, to order-level size and socioeconomic status rerepresentation requirements. 

FAR Case 2021-017: A proposed rule would amend the FAR to partially implement an Executive Order on cyber threats and incident reporting and information sharing for federal contractors and to implement related cybersecurity policies.

FAR Case 2021-019: A proposed rule would amend the FAR to provide standardized cybersecurity contractual requirements across federal agencies for federal information systems by implementing  recommendations received in accordance with paragraph (i) of section 2 of Executive Order 14028 ("Improving the Nation’s Cybersecurity") and paragraphs (a) and (b)(1) of section 7 of the Internet of Things Cybersecurity Improvement Act of 2020.

FAR Case 2021-009: A proposed rule would amend the FAR to implement regulatory changes made by the SBA to update and clarify requirements associated with size and/or socioeconomic status protests in connection with multiple-award contract set-asides and reserves and orders placed under multiple-award contracts. 

Department of Defense FAR Supplement (DFARS)

Final Rules

DFARS Case 2018-D066: A final rule amended the DFARS by replacing all instances of "commercial item"’ with "commercial product" and/or "commercial service.

DFARS Case 2017-D018: A final rule amended the DFARS to implement a section of the NDAA for FY 2017 that makes amendments regarding the treatment of independent research and development expenditures and requires the DCAA to provide an annual report to Congress on independent research and development and bid and proposal expenditures associated with awarded DoD contracts for the prior Government fiscal year. 

DFARS Case 2022-D010: DoD adopted as final, without change, an interim rule amending the DFARS to implement a section of the NDAA for FY 2022 that requires a disclosure from entities that employ one or more individuals who will perform work in the People’s Republic of China. 

DFARS Case 2021-D008: A final rule amended the DFARS to remove clause 252.232–7017 ("Accelerating Payments to Small Business Subcontractors—Prohibition on Fees and Consideration"), which prohibits the contractor requiring any further consideration from or charging fees to the small business subcontractor in exchange for making accelerated payments, because the clause and its proscription are no longer necessary due to other provisions in the FAR. 

DFARS Case 2021-D001: A final rule amended the DFARS to implement a GAO recommendation regarding expediting quick close out procedures. This rule states that the amount of unsettled direct costs and indirect costs to be allocated to the contract, task order, or delivery order will be considered relatively insignificant when the total unsettled direct costs or indirect costs to be allocated do not exceed $2 million. Additionally, DCMA administrative contracting officers may negotiate the settlement of direct and indirect costs for a specific contract, task order, or delivery order to be closed in advance of the determination of final direct costs and indirect rates set forth in FAR 42.705 regardless of the dollar value or percentage of unsettled direct or indirect costs allocable to the contract. 

DFARS Case 2017-D036: A final rule amended Parts 204, 232, and 252 of the DFARS to provide clarifying payment instructions for certain contracts based on the type of item acquired and the type of payment. 

DFARS Case 2022-D021: A final rule amended the DFARS to clarify when a contract administration office has authority to negotiate and settle direct costs questioned in incurred cost audits by adding to section 242.302(b) an additional contract administrative function delegable from a procuring contracting office to a contract administration office.

DFARS Case 2020-D027: A final rule amended the DFARS to to revise the requirements related to the assumption of risk associated with aircraft under DoD contracts due to numerous developments in aircraft contract situations and the emergence of contracts for small, unmanned aircraft.

DFARS Case 2018-D018: A final rule amended the DFARS to implement section 871 of the NDAA for FY 2018, which  requires that the DoD, as part of any negotiation for such software, consider all noncommercial computer software and related materials necessary to meet the needs of the agency throughout the life cycle of the software. The new rule provides direction to the DoD both to improve acquisition planning and to identify and negotiate for software deliverables and license rights at a fair and reasonable price before contract award.

DFARS Case 2019-D009: A final rule amended the DFARS to update the policy and procedures for use of the Supplier Performance Risk System ("SPRS") and to require contracting officers to consider SPRS risk assessments, if available, (a) in the evaluation of a supplier’s quotation or offer and (b) when determining contractor responsibility. 

DFARS Case 2023-D006: A final rule implemented section 842 of the NDAA for FY 2023, which amends 10 U.S.C. 4022(f)(2) to permit the award of a follow-on production contract without the use of competitive procedures, even if an explicit notification was not listed within the request for proposal for the prototype project transaction. 

DFARS Case 2021-D003: A final rule amended the DFARS to to refine the management of undefinitized contract actions (UCAs) as recommended in the DoD Inspector General Audit of Military Department Management of Undefinitized Contract Actions (Report No. DODIG–2020–084). 

DFARS Case 2020-D022: A final rule amended the DFARS to implement section 852 of the NDAA for FY 2020, which transfers responsibilities for carrying out the procurement technical assistance cooperative agreement program from the Director of the Defense Logistics Agency to the Under Secretary of Defense for Acquisition and Sustainment. 

DFARS CASE 2023-D005: A final rule amended the DFARS to  implement a section of the NDAA for FY 2023 that adds New Zealand to the definition of the national technology and industrial base.  

DFARS Case 2017-D028: A final rule amended the DFARS to implement section 846 of the NDAA for FY 2017 that repealed provisions related to major automated information systems. 

DFARS Case 2022-D009: A final rule adopted, with changes, the prior interim rule amending the DFARS to implement section 802 of the NDAA for FY 2022 that restricts the acquisition of personal protective equipment and certain other items from the Democratic People’s Republic of North Korea, the People’s Republic of China, the Russian Federation, and the Islamic Republic of Iran.

DFARS Case 2020-D017: A final rule amended the DFARS to implement section 853 of the NDAA for FY 2020 that requires certain auxiliary ship components to be procured from a manufacturer in the national technology and industrial base. 

DFARS Case: 2022-D006: A final rule amended the DFARS to implement section 803 of the NDAA for FY 2022, which modifies 10 U.S.C. 2380c (redesignated as 10 U.S.C. 3458) to give DoD the authority to acquire innovative commercial products and commercial services through a competitive selection of proposals resulting from a general solicitation and the peer review of such proposals. Section 803 of the NDAA for FY 2022 also repealed section 879 of the NDAA for FY 2017, which authorized a pilot program providing the same authority for a limited period of time. In addition, section 814 of the NDAA for FY 2023 amended 10 U.S.C. 3458 by striking ‘‘fixed-price incentive fee contracts’’ and inserting ‘‘fixed-price incentive contracts,"  and this final rule incorporates this statutory amendment. 

DFARS Case 2024-D001: A final rule amended the DFARS to to add North Macedonia as a new designated country under the World Trade Organization Government Procurement Agreement. 

DFARS Case 2023-D015: A final rule adopted without change, an interim rule amending the DFARS to implement a section of the NDAA for FY 2023 that prohibits the use of funds to knowingly procure any products mined, produced, or manufactured wholly or in part by forced labor from the Xinjiang Uyghur Autonomous Region of the People’s Republic of China. 

DFARS Case 2021-D021: A final rule amended the DFARS to implement section 1025 of the NDAA for FY 2021 that restricts overhaul and repair of a naval vessel in a shipyard outside the United States or Guam. 

DFARS Case 2012-D010: A final rule amended the DFARS to partially implement section 874 of the NDAA for FY 2017 that addresses the inapplicability of certain laws and regulations to the acquisition of commercial products, including commercially available off-the-shelf items, and commercial services.

DFARS Case 2020-D029: Effective January 22, 2024, a final rule amends the DFARS to consolidate existing contract clauses for the management and reporting of Government property into a single contract clause and to replace references to legacy software applications used for reporting Government property within the DoD enterprise-wide eBusiness platform and convert existing form-based processes into electronic processes within that platform. 

Interim Rules

DFARS Case 2022-D009: An interim rule amended the DFARS to implement a section of the NDAA for FY 2022 that restricts the acquisition of personal protective equipment and certain other items from the Democratic People’s Republic of North Korea, the People’s Republic of China, the Russian Federation, and the Islamic Republic of Iran.

DFARS Case 2023-D015: An interim rule amends the DFARS to implement section 855 of the NDAA for FY 2023, which  prohibits the use of funds to knowingly procure any products mined, produced, or manufactured wholly or in part by forced labor from the Xinjiang Uyghur Autonomous Region.

DFARS Case 2021-D023: An interim rule amended the DFARS to implement section 1062 of the NDAA for FY 2021, which provides that none of the funds authorized to be appropriated or otherwise made available for any fiscal year for DoD may be provided to an institution of higher education that hosts a Confucius Institute, defined as a cultural institute directly or indirectly funded by the government of China.

DFARS Case 2020-D011: An interim rule amended the DFARS to implement sections 322(b), (c), and (d) of the NDAA for FY 2020, which prohibit the DoD's procurement of fluorinated aqueous film-forming foam ("AFFF")containing in excess of one part per billion of perfluoroalkyl and polyfluoroalkyl substances after October 1, 2023, unless an exemption applies. Section 322 also requires publication not later than January 31, 2023, of a military specification for a fluorine-free fire-fighting agent for use at all military installations and availability of such agent for use not later than October 1, 2023. After October 1, 2024, fluorinated AFFF may not be used at any military installation, unless the Secretary of Defense waives the prohibition on use.

Proposed Rules

DFARS Case 2022-D006: A proposed rule would amend the DFARS to to implement a section of the NDAA for FY 2022 that authorizes the DoD to acquire innovative commercial products and commercial services using general solicitation competitive procedures, as well as a section of the NDAA for FY 2023 that makes an amendment to that authority.

DFARS Case 2018-D053: A proposed rule would amend the DFARS to to enable the Defense Contract Management Agency (DCMA) to obtain export authorizations from contractors when a contract requires government quality assurance surveillance oversight and has delivery to, or production or performance in, the following government quality assurance countries: Australia, Belgium, Canada, Czech Republic, Denmark, Finland, France, Germany, Greece, Israel, Italy, Republic of Korea, Netherlands, Norway, Poland, Romania, Slovakia, Spain, Sweden, Turkey, and the United Kingdom..

DFARS Case 2021-D021: A proposed rule would amend the DFARS to to implement section 1025 of the NDAA for FY 2021, which amends 10 U.S.C. 8680(a) to restrict the overhaul or repair of a naval vessel in a shipyard outside the United States or Guam.

DFARS Case 2020-D029: A proposed rule would amend the DFARS to consolidate existing contract clauses for the management and reporting of Government property into a single contract clause, to replace references to legacy software applications used for reporting Government property within the DoD enterprise-wide eBusiness platform, and to convert existing form- based processes into electronic processes within that platform.

DFARS Case 2021-D015: A proposed rule would amend the DFARS to implement a section of the NDAA for FY 2021 that provides restrictions on the acquisition of certain covered materials from North Korea, the People’s Republic of China, Russia, and Iran.

DFARS Case 2020-D021: A proposed rule would amend the DFARS  concerning contract clauses regarding the the care and treatment of working dogs provided under the contract after their retirement. 

DFARS Case  2022-D019: A proposed rule would amend the DFARS to supplement the FAR implementation of Executive Order (E.O.) 14005 ("Ensuring the Future Is Made in All of America by All of America’s Workers") addressing domestic preferences in DoD procurements. 

DFARS Case 2023-D009: DoD proposed to revise the DFARS to to implement section 808 of the NDAA for FY 2023, which amends section 818 of Public Law 109–364 to limit the number of low-rate initial production lots associated with a major defense acquisition program to be procured to no more than one when the milestone decision authority authorizes the use of a fixed-price type contract at Milestone B and the scope of the work includes both development and low-rate initial production. This limitation may be waived. 

DFARS Case 2023-D011: A proposed rule would amend the DFARS to implement section 856 of the NDAA for FY 2023 that permanently authorizes and modifies the DoD Mentor-Protégé Program. 

DFARS Case 2018-D074: A proposed would amend the DFARS to implement sections of the NDAA for FY 2018 and 2019 regarding the applicability of certain solicitation provisions and contract clauses to contracts and subcontracts for commercial products, commercial services, and commercially available off-the-shelf items.

DFARS Case 2021-D022: A proposed rule would amend the DFARS to to implement two sections of the NDAA for FY 2021, one section of the NDAA for FY 2022, one section of the NDAA for FY 2023, and one section of the Consolidated Appropriations Act, 2023. These statutes remove limitations and restrictions on certain components that are no longer required and add new limitations on other components, subject to exceptions. 

DFARS Case 2023-D010: A proposed rule would amend the DFARS to to implement section 803 of the James M. Inhofe NDAA for FY 2023, which modifies 10 U.S.C. 3455 to provide additional guidance regarding data requirements to support a determination of commerciality and price reasonableness for certain procurements associated with major weapon systems. 

DFARS Case 2018-D053: The proposed rule concerning export authorizations associated with this case was withdrawn. 

 Other Agencies 

Defense Department 

The DoD is contemplating negotiating and concluding a new Reciprocal Defense Procurement Agreement with Brazil and requestied industry feedback regarding its experience in public defense procurements conducted by or on behalf of the Brazilian Ministry of Defence or Armed Forces.  

Department of Education

The Department of Education proposed an extensive set of modifications to the its Acquisition Regulation (EDAR) to revise aspects of those regulations that are out-of-date or redundant with other Department of Education  policies and procedures and to accurately implement the current FAR and Department policies.  The final rule is effective October 1.

Department of Energy 

The DOE proposed a comprehensive revision of its acquisition regulation (DEAR) in order to update and streamline the policies, procedures, provisions and clauses that are applicable to its contracts, specifically to update or eliminate coverage that is obsolete or that unnecessarily duplicates the FAR and retain only that coverage which either implements or supplements the FAR for the award and administration of the DOE’s contracts. 

Department of Homeland Security

DHS adoptied as final, with only minor changes, the proposed rule amending the Homeland Security Acquisition Regulation (HSAR) in order to implement a new subpart and new contract clause (i) to establish contract termination policies for the United States Coast Guard and (ii) to amend a clause to address the applicability of the Coast Guard's contract termination policy to commercial items.

A final rule amends the DHS's acquisition regulation to address requirements for the safeguarding of Controlled Unclassified Information (CUI) by implementing security and privacy measures to safeguard CUI and facilitating improved incident reporting to DHS  when DHS contractors experience incidents with protected DHS information. 

DHS withdrew a proposed rule originally published in August 2012 titled "Homeland Security Acquisition Regulation (HSAR) Subcontractor Labor Hour Rates Under Time and Materials Contracts (HSAR Case 2010–001)." The original notice of proposed rulemaking proposed to amend HSAR parts 3016 and 3052 to require DHS contracts for time and material or labor hours to include separate labor hour rates for subcontractors and a description of the method that would be used to record and bill for labor hours for both contractors and subcontractors. DHS withdrew this proposed rule because of differing agency priorities and the staleness of the public comments.

DHS also withdrew a proposed rule originally published in June 2010 titled "Limitations on Subcontracting in Emergency Acquisitions (HSAR Case 2009–005)," which proposed to amend the HSAR to limit the use of tiering subcontractors on cost-reimbursement type contracts entered into by the Department to facilitate the response to or recovery from a natural disaster or act of terrorism or other man-made disaster. 

General Services Administration (GSA)

GSAR Case 2022-G513: The GSA proposed to amend the GSAR to remove GSAR Clause 552.232–1 ("Payments") and any corresponding references to the clause because the GSA has determined the existing FAR clause 52.232–1 ("Payments") is sufficient. The GSAR clause requires, in certain transactions, that the Government to pay a contractor without the submission of a proper invoice for non-commercial fixed price contracts for supplies or services; whereas the FAR currently requires that the Government pay a contractor only after receipt of the contractor’s proper invoice or voucher.  

GSAR Case 2023-G506: A final rule amended the GSAR to remove clause 552.232–77 ("Payment by Government Charge Card").  

GSAR Case 2020-G511: The GSA proposed to amend its acquisition regulation (GSAR) to update and clarify the requirements for the use of FSS contracts by eligible non-federal entities, such as state and local governments.

GSAR Case 2019–G503: The GSA amended the GSAR to clarify and streamline the clauses contracting officers should reference in acquisitions for commercial products and services.

GSAR Case 2020-G510: The GSA proposed to amend the GSAR to to standardize and simplify the Multiple Award Schedule clauses for economic price adjustments. The proposed rule would remove certain economic price adjustment requirements within these clauses to better align with commercial standards and practices.

GSAR Case 2022-G517: The GSA proposed to amend the GSAR to add a new provision and clause to identify single-use plastic free packaging availability for products under the FSS with the goal of reducing single-use plastic packaging.

Labor 

The DOL proposed to revise its acquisition regulations (DOLAR) in their entirety to update and streamline agency procurement regulations consistent with the Federal Acquisition Reform Act and FASA in order to remove provisions that are redundant or obsolete and codify the use of certain contractual provisions that DOL has developed and deployed in recent years in order to put potential contractors on notice of these provisions and to formalize their usage, including provisions relating to: government property, continuity of operations, system requirements, records management, telework policy for contractor personnel, submission of invoices, mandatory training for contractors, OCIs, and changing the scope of a contract. The proposed revisions also remove provisions in the current DOLAR that are DOL internal operating procedures, which need not be published in the C.F.R. in order for them to take effect. The current DOLAR supplements the FAR to address matters specific to the DOL relating to its procurement of goods and services. It also includes certain rules governing private entities doing business with DOL. 

NASA

Effective October 19, a final rule amends the NASA Federal Acquisition Regulation Supplement (NFS) to conform to changes in the FAR that reflect an updated "commercial item" definition pursuant to a section of the John S. McCain National Defense Authorization Act (NDAA) for FY 2019.

NASA  issued a final rule revising the NFS to reflect updates to NASA’s Small Business Mentor Protégé Program. 

NASA proposed to amend the NFS to reflect updates to NASA’s Mentor Protégé Program (MPP) including: the requirement of Small Business Specialists’ concurrence on the signed letter of endorsement; requirements associated with credit received towards subcontracting goals; the change of the MPP reporting requirement from semi-annually to annually; identification of the NASA Mentor Protégé Program Office; and clerical, semantic improvements. NASA also proposed to amend the NFS language to reflect the annual negotiation of its small business percentage goals. Lastly, the NFS will be amended to emphasize collaboration amongst representatives from the Office of Small Business Programs, Office of Procurement, and Program Offices to reduce barriers to entry and to opportunities for all small business concerns and Historically Black Colleges and Universities or Minority Institutions.

NASA proposed to amend the NFS by removing NFS 1831.205–671 and NFS 1852.231–71 ("Determination of Compensation Reasonableness") because they provisions exceed the requirements adequately covered in FAR 52.222–46 ("Evaluation of Compensation for Professional Employees"

Effective December 20, a final rule amends the NASA acquisition regulation supplement (NFS) to update the policy concerning the NASA Ombudsman Program.  

Small Business Administration (SBA)

The SBA increased 144 of its its employee based size standards (and retaining 268 others) for NAICS sectors related to Mining, Quarrying, and Oil and Gas Extraction (Sector 21); Utilities (Sector 22); Manufacturing (Sector 31–33); Transportation and Warehousing (Sector 48–49); Information (Section 51); Finance and Insurance (Sector 52); Professional, Scientific and Technical Services (Sector 54); and Administrative and Support, Waste Management and Remediation Services (Sector 56). The SBA also retained the current 500-employee size standard for federal procurement of supplies under the nonmanufacturer rule.

The SBA amended its regulations to provide procedures for the OHA to hear appeals from protest determinations regarding the status of a concern as a certified HUBZone small business concern. 

The SBA issued a final rule that adopted, without change, three interim final actions dated November 17, 2022, that adjusted monetary-based industry size standards (i.e., receipts- and assets-based) for inflation: (i) an additional 13.65 % inflation increase to the industry-based monetary small business size standards to account for the inflation that occurred since the last adjustment to size standards for inflation in 2019; (ii) inflation adjustments to three program-specific monetary size standards (the size standards for sales or leases of government property, the size standards for stockpile purchases, and the alternative size standard based on tangible net worth and net income for the SBIC program; and (iii) inflation adjustments to the economic disadvantage thresholds applicable to the 8(a) Business Development and Economically Disadvantaged Women-Owned Small Business programs, and the dollar limit for combined total 8(a) contracts. 

The SBA made several changes to the ownership and control requirements for the 8(a) Business Development program, including recognizing a process for allowing a change of ownership for a former Participant that is still performing one or more 8(a) contracts and permitting an individual to own an applicant or Participant where the individual can demonstrate that financial obligations have been settled and discharged by the Federal Government. The rule also makes several changes relating to 8(a) contracts, including clarifying that a contracting officer cannot limit an 8(a) competition to Participants having more than one certification and clarifying the rules pertaining to issuing sole source 8(a) orders under an 8(a) multiple award contract. The rule also makes several other revisions to incorporate changes to SBA’s other government contracting programs, including changes to implement a statutory amendment from the NDAA for FY 2022, to include blanket purchase agreements in the list of contracting vehicles that are covered by the definitions of consolidation and bundling, and to more clearly specify the requirements relating to waivers of the nonmanufacturer rule. 

The SBA amended its regulations to establish a certification program for VOSBs and SDVOSBs to implement section 862 of the NDAA for FY 2021. Subsequently, the SBA issued quite a number of corrections to this rule.

The SBA amended its regulations to implement provisions of the NDAA for FY 2020 in order to permit a prime contractor with an individual subcontracting plan to apply credit for subcontracts to small businesses at lower tiers toward its subcontracting goals by incorporating the lower-tier subcontracting performance into the prime contractor's subcontracting-plan goals.  

The SBA revised its white paper explaining how it establishes, reviews, and modifies small business size standards, including changes from the SBA’s 2019 Revised Size Standards Methodology, which guided the SBA’s recently completed second five-year review of size standards as required by the Small Business Jobs Act of 2010.

The SBA proposed to amend its small business size regulations to increase the alternative size standard for its 7(a) Business and Certified Development Company Loan Programs by 34.46% to account for inflation that has occurred since the size standard’s establishment in 2010. The inflation adjustment would increase the size standard’s level for tangible net worth to $20 million and for net income to $6.5 million. SBA also is adjusting for inflation the applicable statutory limits for contract size under the Surety Bond Guarantee Program. The adjustment would increase the contract limit to $9 million and to $14 million for Federal contracts if a federal contracting officer certifies that such a guarantee is necessary. 

USAID

A final rule amended the United States Agency for International Development's ("USAID") Acquisition Regulation ("AIDAR") regarding contractor requirements on foreign tax reporting, conference planning, and trade and investment activities in order to bring the AIDAR into compliance with revised agency policies and procedures and statutory requirements. 

Veterans Affairs

The VA issued a final rule amending the its Acquisition Regulation (VAAR) by adding a part covering Acquisition of Information Technology and revising coverage concerning Other Contracts for Goods and Services involving mandatory information, privacy, and security requirements to include policy concerning VA sensitive personal information, information security, and liquidated damages requirements for data breach.

 

This website links to resources on the web concerning government contracting. It is not intended to provide legal advice. Moreover, I do not vouch for the completeness, currency, or accuracy of the sites to which it links. If you have  comments, suggestions for new links, or corrections, please email me.