On February 4, 2019, PilieroMazza submitted comments on RIN 3245-AG86, Proposed Rule National Defense Authorization Acts of 2016 and 2017, Recovery Improvements for Small Entities After Disaster Act of 2015, and Other Small Business Government Contracting.

Includes our comments on:

  • SBA’s Proposed Changes About Subcontracting Plans Provide Necessary Clarification
  • SBA’s Contracting Preferences for Small Businesses in Disaster Areas Are Welcome
  • SBA’s Clarification Regarding the Nonmanufacturer Rule and Information Technology Value Added Resellers Is Beneficial
  • Setting Aside an Order Under a Multiple-Award Set-Aside Contract
  • SBA Should Provide Further Clarifications to Its Proposed Rule on Recertification of Size and Status
  • SBA Should Not Require Mandatory Limitations on Subcontracting Compliance Disclosures
  • Exclusions from the Limitations on Subcontracting Calculation Are Welcome
  • SBA’s Proposed Changes to the Ostensible Subcontractor Rule Are Unnecessary and Will Harm Small Businesses
  • SBA Reasonably Proposes to Remove the Kit Assembler Provision
  • The Proposed Clarification About when Size Is Determined Is Helpful
  • Clarification Where One Acceptable Offer Is Received on a Set-Aside
  • The SBA Should Repeal the Presumption That Minority Shareholders Control a Business when No Majority Shareholder Exists