TCFD Recommendations – Analysis and Next Steps

The federal government has identified purported ‘waste, fraud, and abuse’ in small business programs as a major focus of its current enforcement efforts. As it relates to federal procurement, we have seen audits and investigations rolled out not only of active participants in the Small Business Administration’s 8(a) Business Development Program but also reviews of various types of small business contracts (such as 8(a) sole source and set-aside awards, preference-based awards, and small business set-aside awards over particular values). Join Crowell & Moring as we discuss what aspects of contract performance and teaming arrangements are being scrutinized (e.g., size/status eligibility, limitations on subcontracting compliance, reasonableness of market rates, etc.) and how these considerations can impact both small government contractors holding the prime contracts under review and their subcontractors. ...