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The Small Business Runway Extension Act Is One Step Closer to Take Off

Client Alert | less than 1 min read | 07.08.19

On June 24, 2019, the U.S. Small Business Administration published a rule proposing to amend the time period for calculating average annual receipts for SBA’s receipts-based size standards from three to five years.  This rule would implement the congressional intent behind the Small Business Runway Extension Act of 2018, which the SBA previously instructed did not permit small businesses to immediately begin certifying against a five-year time period.  In the proposed rule, the SBA again warns that the three-year calculation period continues to apply to any offer submitted prior to the effective date of a final rule.  Comments on the proposed rule are due by August 23, 2019.

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Client Alert | 2 min read | 07.15.26

CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations

As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights....