In a significant new proposed rule, the Small Business Administration (SBA) proposes to alter a number of regulations, including those governing size recertifications following mergers and acquisitions. We have previously discussed (in this article and this article) recent decisions of the SBA Office of Hearings and Appeals (OHA) and Government Accountability Office (GAO), which held that such recertifications generally are not required in connection with pending proposals under General Services Administration (GSA) Federal Supply Schedule (FSS) orders and Blanket Purchase Agreements (BPAs).
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