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As we previously reported, on January 16, 2026, the Department of War (DoW) announced an audit of 8(a) sole source awards over $20 million, joining the previously-announced audits by the Small Business Administration (SBA) and U.S. Treasury Department (discussed here and here).  A DoW memorandum also dated January 16, 2026 but only recently made public reveals that this audit is much broader in than originally announced.  Any active 8(a) sole source contract, 8(a) set-aside contract, or small business set-aside contract over $20 million is under scrutiny. Continue Reading DoW’s Previously Announced 8(a) Audit Expanded to Include All Small Business Set-Aside Awards over $20 Million

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The Small Business Administration (SBA) has rolled out changes to its 8(a) Program even as it suspends 8(a) participants for failure to respond to the SBA’s December 5, 2025 8(a) audit letters.Continue Reading 8(a) Participants – and the 8(a) Program – Under the Microscope or on the Chopping Block

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On December 5, 2025, the Small Business Administration (SBA) sent letters to 4,300 current and recent participants in the 8(a) Business Development Program requiring production by January 5, 2026, of financial records, contracting and subcontracting agreements, and employee records.  Below we discuss the genesis of the U.S. Government’s focus on fraud in small business programs, the new SBA request for documents, the coming Treasury audit of preference-based contracts, and more.Continue Reading SBA Office of General Counsel Audit of Participants in the 8(a) Program and Beyond

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On September 4, 2025, the Small Business Administration’s (SBA) Office of Hearings and Appeals (OHA) granted an appeal challenging SBA’s determination that a service-disabled veteran did not control an entity applying for Service-Disabled Veteran-Owned Small Business (SDVOSB) status based on a minority owner’s ability to block certain actions in the matter of VSBC Appeal of: Blue Skye Foods, LLC, SBA No. VSBC-442-A.Continue Reading SBA’s OHA Further Defines Extraordinary Action in SDVOSB Appeal

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On August 22, 2025, the Small Business Administration (SBA) published a proposed rule that would raise the receipts-based small business size standards across 259 industries and the asset-based size standard across 4 industries. The proposed rule aims to provide greater opportunity for growing small businesses to retain their small business status longer and continue to benefit from SBA loan programs and federal contracting opportunities reserved for small businesses.Continue Reading SBA Proposes Increases to Small Business Receipts-Based Size Standards to Promote More Competition for Small Business Set-Aside Contracts

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On May 12, 2025, the U.S. Small Business Administration (SBA) announced that it is holding a tribal consultation meeting and requesting comments and input on topics relating to the 8(a) and mentor-protégé programs. The tribal consultation will be held on June 13, 2025 in Anchorage, Alaska, and SBA is anticipating that the meeting will cover a range of topics relevant to 8(a) and mentor-protégé program participants.Continue Reading Tribal Consultation Meeting for 8(a) Business Development and Mentor-Protégé Programs Provides Insight Into SBA Priorities Under the New Administration

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On February 24, 2025, the Small Business Administration (SBA) issued a “Day One” memo outlining SBA Administrator Kelly Loeffler’s priorities. 

The “Day One” memo highlights SBA’s focus on the Trump administration initiatives—including implementing President Trump’s executive orders; mandating that all non-exempt employees return to full-time, in-office work; and working closely with the Department of Government Efficiency (DOGE) in accomplishing accountability, transparency, and efficiency.  SBA will relocate regional offices “currently based in sanctuary cities” to what it characterizes as “less costly, more accessible locations in communities that comply with federal immigration law.”Continue Reading SBA Issues “Day One” Memo – with a Particular Emphasis on Rooting out Fraud

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On December 17, 2024, the Small Business Administration (SBA) published a final rule amending multiple aspects of all of the SBA’s small business size and status programs.  Among other notable changes, SBA (1) introduced a new rule that changes the impact of a recertification as other than small or as other than the relevant small business status following a merger or acquisition, and (2) introduced a standardized set of permissible negative controls for minority shareholders in all types of small businesses, thereby significantly expanding the controls investors may have in service-disabled veteran-owned small businesses (SDVOSBs), women-owned small businesses (WOSBs), and participants in the SBA’s 8(a) Business Development Program. Continue Reading Brace for Impact: Final SBA Rule Changes to Recertification and Negative Controls Will Reverberate in GovCon M&A and Investment Market

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On August 8, 2024, the U.S. Attorney’s Office for the Central District of California announced a $6.3 million False Claims Act settlement with West Coast Dental Administrative Services LLC (formerly West Coast Dental Services Inc.) and its founders and former owners due to seven improper second-draw Paycheck Protection Program loans received by West Coast Dental and affiliated dental offices. Continue Reading California Dental Offices Settle FCA Allegations Regarding Second-Draw PPP Loans for $6.3M