New Rule on Subcontracting Compliance from SBA OHA Ruling

Schwabe – On May 2, 2025, in Size Appeal of Bowhead Enterprise, Science, and Technology, LLC, the Small Business Administration (“SBA”) Office of Hearings and Appeals (“OHA”) ruled that for service and manufacturing contracts, there cannot be a finding of an ostensible subcontractor if the contractor is in compliance with the applicable limitations on subcontracting requirement.