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.

SBA has already issued a thorough body of regulations dealing with the limitations on subcontracting, and SBA has the authority under the Small Business Act to mandate the level of performance by prime contractors on small business set-aside contracts. Therefore, SBA’s regulations represent the appropriate standard for the limitations on subcontracting, and we agree with the FAR Council’s efforts to conform the FAR with SBA’s rules. However, as discussed in our comments, we believe the proposed FAR clauses require further revisions to ensure they are consistent with the existing SBA regulations. Read our full comments here.