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By: Jake Noe and Brad Reaves If you’ve been following the Revolutionary FAR Overhaul, you’ve probably heard about the major rewrite of FAR Part 19. But if this update slipped under your radar, here’s what you need to know: on September 26, 2025, the Federal Acquisition Regulatory Council officially issued an overhaul to FAR Part 19 — a move with real implications for small business government contractors. This alert highlights four key changes every small business should understand.
1. A Streamlined, Smarter Structure The first thing you’ll notice is organization. FAR Part 19 has been retitled from “Small Business Programs” to simply “Small Business.” More than a cosmetic fix, the entire part has been reorganized around the acquisition lifecycle— moving logically from Presolicitation, to Evaluation and Award, and finally to Postaward. In addition:
The result? A more intuitive, streamlined framework that should make navigating FAR Part 19 a little less of a headache. 2. The “Rule of Two” Survives — With a Twist Good news for small businesses: the Rule of Two remains in place for acquisitions above the Simplified Acquisition Threshold (SAT) — which rises to $350,000 on October 1, 2025. However, there’s a notable shift when it comes to multiple-award contracts (MACs). Agencies now have discretion to set aside individual orders for small businesses — and these decisions are no longer protestable. So, while the rule survives, how it’s applied will depend more than ever on agency strategy. 3. Big Shifts for the 8(a) Program Perhaps the most consequential change involves the 8(a) program. Under the old rule — “Once 8(a), Always 8(a)” — follow-on contracts stayed in the 8(a) program unless the Small Business Administration (SBA) formally released them. Now, agencies can automatically release follow-on contracts from 8(a) if they’re being set aside for another socioeconomic program (HUBZone, SDVOSB, or WOSB) — no SBA approval required. Another key change: for contracts below the competitive thresholds, Contracting Officers must now consider competitive 8(a) awards through governmentwide vehicles before opting for a sole source. This should lead to more opportunities — and more competition — in the 8(a) space. 4. New Rules for Recertification Finally, the rewrite reshapes how size and status recertifications are handled under MACs. Previously, contracting officers could request recertifications at the task or delivery order level. Not anymore. Under the new rule, size and status are determined at the master contract level— and only refreshed when major contract-level events occur, such as an option exercise, novation, or merger/acquisition. In practical terms: your small business status will generally be locked in when your initial proposal (including price) is submitted. The Bottom Line With this rewrite, FAR Part 19 becomes more streamlined, modern, and — in some ways — more flexible. But these changes also carry new risks and opportunities for small businesses navigating the federal marketplace. If you’d like to understand how to position your company for success under the Revolutionary FAR Overhaul, contact Reaves GovCon Government Contracts Attorneys: Brad Reaves and Jake Noe. Think outside the Beltway. Disclaimer: Nothing in this article is, or is intended to be, legal advice. Comments are closed.
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