SAM.gov is something every federal government contractor has to deal with for actions like searching solicitations and registering to be a federal contractor. As every federal contractor wanting to do business with the federal government has to register on SAM, the questionnaires on SAM must cover a wide array of different possible businesses and business structures. As much as SAM tries to make sure to cover all the possibilities, inevitably, there are some questions that could have so many answers that contractors will often have their own questions about how to answer them properly. One of the most common questions that come up from contractors during SAM registration is “what do I put for Immediate Owner on SAM?” or “what does Highest-Level Owner mean?”
Continue reading…Event Announcement: GovCon Roundup Live, July 15, 1:00pm EDT, Expanding VOSB and SDVOSB Opportunities & Navigating the SBA Certification Minefield
Please join me on the GovCon Roundup Live, with Carroll Bernard and Steven Koprince to discuss several important developments affecting veteran-owned small businesses in federal contracting, including
- The bipartisan Contract Our Veterans Act of 2026.
- Critical compliance issue for veteran-owned businesses pursuing VA set-asides: the frequently overlooked limitations on subcontracting certification requirement under VAAR 852.219-75.
- Why SBA’s strict “unconditional control” rules make certification extremely difficult for franchises
- Why a veteran must be listed as the company’s highest officer, such as CEO, in the governing documents
- What “fatal flaws” can undermine an appeal after a certification denial
Here are the details:
- Wednesday, July 15, 2026
- 1:00 – 2:30 PM Eastern
- Free to attend
Here is the link for registration:
https://lnkd.in/gKJVaqBg
Happy Independence Day from SmallGovCon!
We at SmallGovCon want to wish you and yours a wonderful Independence Day. Be safe this weekend and remember what the day is all about. It is a time to remember what unites as a nation, and consider our shared values and ideals. We hope you have a chance to relax, spend time with family and friends, and enjoy the 4th! We leave you with these words from the Declaration of Independence:
We hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness.
Preamble to the Declaration of Independence
COFC: Limitation on Subcontracting Certification Trips Up Contractor Where Solicitation Requires it to be Signed and Attached
When it comes to federal contracting, there are parts that are very detail-oriented. Countless signatures for countless certifications. We certainly empathize with contractors on this aspect of federal contracting. But just because we are empathetic does not mean that a contractor can ignore such requirements. In a recent decision, Revelations Counseling & Consulting, LLC v. United States, 180 Fed. Cl. 721 (2026), the Court of Federal Claims (COFC) made it very clear: Where the solicitation says sign the certification and include it in the proposal, sign it and include it in the proposal. Anything less and not only should you expect a rejection, the agency is often required to reject the proposal. In this case, the certification was a VA limitations on subcontracting clause that has cropped up multiple times lately in our practice and is an important part of small business contracting. We look at that decision today.
Continue reading…SmallGovCon Week in Review: June 22-26, 2026
Happy Friday! With June wrapping up, we’ve officially reached the halfway point of the year. Mid-year is the perfect time for federal government contractors to focus on the goals ahead and prepare for new opportunities in the months to come. Here’s to finishing June strong and carrying that momentum into a productive and successful second half of 2026! We hope you have a wonderful weekend.
This week in federal government contracting news, a good chunk of the Revolutionary FAR Overhaul (aka “FAR 2.0” or the “RFO”) makes its way into formal rulemaking procedures, NASA expands total awards and introduces thousands of new awardees for SEWP (Solutions for Enterprise-Wide Procurement)–NASA’s premier Government-Wide Acquisition Contract, the White House accelerates the governmentwide shift to post-quantum cryptography and stirs up some controversy with a no-bid contract award for its Reflecting Pool renovations, and GAO identifies some anticipated procurement challenges of cloud computing and also, reflects on 2025’s FraudNet Activity Report. But that’s certainly not all. Take a look at this week’s articles for more on these and other happenings in the federal procurement landscape this week.
Continue reading…Formal Revolution: FAR Council Releases Proposed Formal Rules to Start RFO Rulemaking Process
The FAR Council has released its first batch of proposed rules to amend the Federal Register to implement the changes to the Federal Acquisition Regulation (FAR) to implement the executive order on Restoring Common Sense to Federal Procurement. In this post, we will provide an overview of how the RFO is being implemented as part of the formal rulemaking process. Overall, the proposed regulation seems to follow the vast majority of the proposed language that was already issued under the RFO. We’ve discussed some of those changes in past blog posts. For background, our earlier posts regarding various aspects of the RFO can be found here: Executive Order, Overview of FAR 2.0, FAR Part 6, FAR Part 19 and the Once 8(a) Rule under Part 19, FAR Part 12, FAR Part 15, FAR Part 33, . But this post notes some changes as compared to the original version of the RFO.
Continue reading…“I Could Have Competed” Won’t Cut It: COFC Requires Showing Contractor Could Perform Work if it Wants to Protest Solicitation Terms
You have your eye on a solicitation. You know the work, you know the customer, and you are certain that you would be a front-runner for the award. Then, you learn that the agency is limiting competition for the procurement, and you can no longer compete for the contract. Immediately, you think that the agency must have made a mistake. After all, you were fully prepared to submit a proposal and perform the work. But is believing you could have competed for the contract and won the award enough to satisfy the requirements for filing a bid protest? A recent COFC decision answers this question.
Continue reading…