On February 4, 2019, PilieroMazza submitted comments on RIN 3245-AG86, Proposed Rule National Defense Authorization Acts of 2016 and 2017, Recovery Improvements for Small Entities After Disaster Act of 2015, and Other Small Business Government Contracting.

Includes our comments on:

  • We Support the FAR Council’s Revisions to FAR 52.219-4, But This Clause Requires Further Modifications to Align with SBA’s Limitations on Subcontracting Rules for HUBZone Joint Ventures
  • The FAR Council Should Propose Revisions to the HUBZone Price Evaluation Preference Clause
  • The Proposed Nonmanufacturer Rule FAR Clause Needs Revision to Conform to SBA’s Nonmanufacturer Rule
  • The Limitations on Subcontracting Should Not Be Applied to Any Contracts Below the Simplified Acquisition Threshold