Some of you may recall the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2014 from nearly a decade ago. It amended the Small Business Act (SBA) to allow a contractor, under certain circumstances, to receive credit towards its subcontracting plan goals for awards made to small businesses at any tier under the contract. The Small Business Administration issued a final rule in 2016 to implement this reform. The Federal Acquisition Regulation (FAR), however, has significantly lagged behind the SBA regulations, and continues to restrict small business subcontracting credit to first-tier awards.
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