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SBA Proposes Fundamental Revision to Subcontract Reporting

October 8, 2015

On October 6, 2015, the SBA issued a proposed rule to change the way prime contractors report how they complied with individual subcontracting plan goals by allowing primes to receive credit for awards made at any subcontracting tier (instead of first-tier only). As part of this proposed change, primes would have to incorporate the subcontracting plan goals of their lower-tier subcontractors into their individual subcontracting plans and would become responsible for ensuring that subcontractors adopt and comply with their plans.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Olivia Lynch
Partner – Washington, D.C.
Phone: +1.202.624.2654
Amy Laderberg O'Sullivan
Partner – Washington, D.C.
Phone: +1.202.624.2563