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SBA’s July 2013 Small Business Subcontracting Revisions Finally Implemented in the FAR

Client Alert | less than 1 min read | 07.21.16

On July 14, 2016, DoD, GSA, and NASA published a final rule implementing numerous updates to the FAR to account for regulatory changes affecting the small business subcontracting requirements made by the SBA dating back to July 2013. These changes, which become effective November 1, 2016, range from requiring prime contractors to assign NAICS codes to subcontracts, to providing contracting officers the discretion to establish subcontracting goals at the order level of IDIQ contracts, to protecting subcontractors’ ability to discuss payment or utilization matters with the contracting officer.

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Client Alert | 3 min read | 07.10.26

Federal Circuit Clarifies Application of Blue & Gold: Proposal Submission Deadline, Not Award, is the Operative Time for Filing

In Utech, Inc. v. United States, No. 24-1586 (Fed. Cir. June 24, 2026), the U.S. Court of Appeals for the Federal Circuit clarified that in most cases, a pre-award protest must be filed before the proposal submission deadline to avoid the Blue & Gold waiver rule.  This decision, while nonprecedential, is in line with U.S. Government Accountability Office (GAO) precedent, which has long held that pre-award protests must be filed before the proposal submission deadline....