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Important Note

TGIC Exchange Brief Small Business Regulatory Update November 10, 2016 Terence Murphy / (757) 624.3139 / tmmurphy@kaufcan.com. Important Note.

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Important Note

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  1. TGIC Exchange BriefSmall Business Regulatory UpdateNovember 10, 2016Terence Murphy / (757) 624.3139 / tmmurphy@kaufcan.com

  2. Important Note The contents of this presentation are intended for general information only and should not be construed or relied upon as legal advice nor as a legal opinion on any specific facts or circumstances. If you need legal advice concerning your specific circumstances, please consider contacting Kaufman & Canoles, P.C.

  3. SBA Final Rule Implementing 2013 NDAA • 81 Fed. Reg. 34,243 (May 31, 2016) (effective June 30, 2016) • Limitations on subcontracting • Similarly situated entities

  4. SBA Final Rule Implementing 2013 NDAA • Limitations on subcontracting • Subcontracting limitations now based on total contract value • Percentage of prime expenditure on subs based on cost of contracts (excluding cost of materials when applicable) cannot exceed: • 50% for services and supply • 85% for general construction • 75% for specialty trade

  5. SBA Final Rule Implementing 2013 NDAA • Similarly Situated Entities • Work subcontracted to “similarly situated entities” counts as work done by the small business prime contractor • “Similarly Situated Entity” defined as a “small business concern subcontractor that is a participant of the same SBA program that qualified the prime contractor as an eligible offeror and awardee of the contract.” • Must also qualify as “small” based on the NAICS code prime contractor assigned to the subcontract

  6. SBA Final Rule Implementing 2013 NDAA • Penalty for violating the new rule • Greater of $500,000 or the dollar amount spent in excess of the limitations • Possible suspension and debarment • Practical Note: SBA regulation only; not yet in FAR • Ask CO question in proposal process whether recognition of this change

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