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Medium urgency

SBA OHA Confirms That the Submission Date for a Proposal with Pricing Controls Size Determination - Government Contracts Legal Forum

Detected July 6, 2026 · in Government Contracting (SAM/FAR)

SBA OHA ruling clarifies that for size determinations involving pricing controls, the relevant proposal submission date is the date the offeror submits its proposal, not the date of any subsequent pricing control submission.

Aforeworn detected this change in the Government Contracting (SAM/FAR) space on July 6, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated Medium urgency. Small businesses competing for set-aside contracts where pricing controls (e.g., price reasonableness, cost accounting standards) apply. should confirm how it applies to their specific situation before acting. There is a time constraint attached: Immediately for any ongoing or upcoming proposals; apply to all future submissions.. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors Government Contracting (SAM/FAR) continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.

What changed

The SBA Office of Hearings and Appeals (OHA) confirmed that the 'submission date' for size determination purposes is the date the proposal is submitted, even if pricing controls are submitted later.

Who it affects

Small businesses competing for set-aside contracts where pricing controls (e.g., price reasonableness, cost accounting standards) apply.

What you must do

Review your proposal submission dates and ensure that size status is determined based on the proposal submission date, not the date of pricing control submissions.

Deadline

Immediately for any ongoing or upcoming proposals; apply to all future submissions.

Source: https://news.google.com/rss/articles/CBMijwJBVV95cUxOVVZnR0F6azcyVWxYd0ZhQ2FzN2QtdmRTVHRiOUxUTkxjYndqRjh0Ukhva1FuMmt1TkdWejR3eWV6Ny1nTDZMWUM2d29Oa254NlJoaEZsczNwMXZtYjlFendfX182VWhHWTRzWU1wN2ZocmNnT3haeFREb3BSQ25lTFdkcVJMQXQzOW1yU3NXRGsxcmRrazcxeVkyanE3ZDk0S0VHWGNPTW1EZ0VaX2NCRGpzc29GMkdqMzhLeDQ5RlhYREdBWWE2SkZzcnNBZ201MlpxOWZrd1AydjluQXVGdmo0UEd0VEtqeXoxY19wZW8xUnlIZDhUbjFwT05tSlFqQkJJb0djNE8tZzh6c3RB?oc=5

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