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Author: laura long

SBA Launches New Audit of Economically Disadvantaged Women-Owned Small Businesses

The Small Business Administration (SBA) has expanded its review of socio-economic contracting programs to include the Economically Disadvantaged Women-Owned Small Business (EDWOSB) program. (Federal News Network June 12, 2026)

Earlier this week, SBA emailed EDWOSB participants and requested that they complete a survey and submit personal and business tax returns for the past three years by June 30. (ibid)

In the email, SBA explained the purpose of the review:

“Pursuant to 13 C.F.R. § 127.400, SBA is conducting a program examination to verify that your firm continues to meet the requirements of the Economically Disadvantaged Women-Owned Small Business (EDWOSB) program,” wrote the agency’s compliance division within the Office of Government Contracting and Business Development. “Specifically, SBA will be verifying that your firm continues to meet the requirement that the woman or women that own at least 51% of the firm are economically disadvantaged, as set forth in 13 CFR 127.203.” (ibid)

Similarities to the 8(a) Program Audit

This review follows SBA’s recent audit of the 8(a) Business Development Program.

In December, SBA requested information from more than 4,300 8(a) firms, including employee lists, bank statements from the previous three fiscal years, and copies of all 8(a) contracts. As a result of that review, SBA suspended more than 1,100 firms and ultimately terminated 154 companies from the program. (ibid)

SBA Proposes Changes to 8(a) Eligibility Requirements

SBA continues to revise the 8(a) Business Development Program. The agency recently released a proposed rule that would change how individuals qualify for the program.

Under the proposal:

“SBA says ‘individuals will no longer be considered” “socially disadvantaged,” and therefore eligible for the 8(a) program, simply because they are a member of a racial minority group. Likewise, no individual may be barred from the 8(a) program simply because they are white. Instead, all applicants will be required to prove their social disadvantage status by submitting verifiable, fact-based evidence.’” (ibid)

The proposed changes would apply only to individually owned firms. SBA would not change eligibility standards for businesses owned by Indian tribes, Alaska Native Corporations (ANCs), Native Hawaiian Organizations (NHOs), or Community Development Corporations (CDCs). (ibid)

Current individually owned 8(a) participants would not be affected. (ibid)

Comments on the proposed rule are due by July 13.

Reactions to the Proposed Rule

Sen. Ed Markey (D-Mass.), ranking member of the Senate Small Business and Entrepreneurship Committee, criticized the proposal. (ibid)

“The SBA’s proposed rule grossly diminishes the history of systemic racial and ethnic discrimination in the United States. Congress created the 8(a) Business Development Program nearly half a century ago to provide entrepreneurs who have faced historic and present-day discrimination with opportunities to partner with the federal government and support to help grow their businesses,” Markey said. (ibid)

“To be clear, the 8(a) program has always been open to anyone that can prove they’ve experienced prejudice or cultural bias, including in education, employment and entrepreneurship. Now, the SBA proposes to define discrimination based on its political whims and allow applicants to self-certify their eligibility. Instead of fighting to right historic wrongs and enable more job creators to grow and thrive, this administration is once again choosing to distort reality to perpetuate its hateful — and harmful — agenda.” (ibid)

Shane McCall, partner at Koprince McCall Pottroff, noted that SBA’s proposal builds on the 2023 Ultima decision. (ibid)

“However, the proposed rule includes a big change in standards for social disadvantage that mostly stem from racial quotas from government or private entities,” McCall said. (ibid)

“Examples include ‘unlawful diversity, equity, and inclusion programs or policies; unlawful affirmative action programs or policies; race-based quotas, set-asides, or hiring targets; or, any government or private entity policies or programs that favored some groups over others on the basis of race.’ We also need to know how SBA will apply these rules.” (ibid)

Questions About the EDWOSB Audit Process

Industry participants have raised concerns about the audit process.

One executive, who requested anonymity, said the review seemed unexpected because the company had recently renewed its certification and remained certified for another three years. (ibid)

The executive also questioned SBA’s use of SurveyMonkey to collect sensitive financial information, including:

  • Cash balances in savings and checking accounts
  • Retirement account information
  • Stock, bond, and mutual fund holdings
  • Life insurance policies with cash surrender value
  • Home ownership, mortgage balances, and property values (ibid)

The survey also asks:

• Has the Qualifying Owner transferred any assets to any immediate family member for less than fair market value in the last two years?

• Do you have any retirement accounts? And if so, provide a list and how much money is in each account.

• Do you have any stocks, bonds or mutual funds? And if so, provide a list, a corresponding number of shares you own and total dollar value for each.

• Do you have a life insurance policy that has a cash surrender value?

• Do you own your primary residence? If so, what is the mortgage of your residence and what is the current value of your residence? (ibid)

The executive said:

“It makes me wonder how much time and effort has been put into this and makes me question the credibility of whatever results we are provided post-evaluation. Will the SBA feed my data into an algorithm or artificial intelligence to determine program eligibility? Or will a human evaluate? Are they comparing our new information with the information provided at application? Or is this a separate examination completely?” (ibid)

SBA did not respond to requests for comment.

Growth of the Women-Owned Small Business Program

The Women-Owned Small Business (WOSB) program has grown significantly during the last decade.

Federal data shows:

  • 1,410 new WOSB firms entered the federal market in fiscal 2023.
  • 1,183 entered in 2022.
  • 1,276 entered in 2021. (ibid)

Although agencies failed to meet the governmentwide 5% contracting goal between 2020 and 2024, contract dollars awarded to WOSBs increased substantially. (ibid)

According to SBA’s June 2025 procurement scorecard:

  • Agencies awarded a record $31.7 billion to WOSBs in fiscal 2024.
  • Agencies awarded $27.1 billion in fiscal 2020.(ibid)

Leadership Connect reports that contracting activity with EDWOSBs has declined so far in fiscal 2026:

  • 17 awards totaling $2.3 million during the first eight months of FY 2026.
  • 35 awards totaling $8.7 million during the same period in FY 2024.
  • 29 awards totaling $4.7 million during the same period in FY 2025. (ibid)

Certification and Audit Outcomes

Concerns about program abuse prompted SBA to strengthen certification requirements in 2020. The agency now requires firms to obtain certification through SBA’s online platform or an approved third-party certifier and to recertify every three years. (ibid)

SBA identified two possible outcomes for the current audit:

Continued Certification

“If SBA determines that the firm continues to meet program eligibility requirements, SBA will provide a written notice of continued certification in your firm’s record within MySBA Certifications, and the firm will maintain its certified EDWOSB status in SBS.” (ibid)

Proposed Decertification

“If you fail to submit your program examination response within the required timeframe or SBA determines the firm no longer meets program eligibility requirements, SBA will notify you that your firm has been proposed for decertification from the EDWOSB program in accordance with 13 CFR 127.405.”

The notice will explain the reasons for proposed decertification and require a written response within 20 calendar days. SBA may draw adverse conclusions if a firm fails to cooperate or provide requested information. (ibid)

SBA also stated that firms may voluntarily withdraw from the program before the audit concludes.

McCall summarized the significance of the review:

“While I’ve seen nothing official, it appears that SBA is auditing the economic disadvantage for all EDWOSB participants. This means those companies will have to provide backup documentation showing they meet the EDWOSB economic disadvantage requirements. Those rules are basically the same as the 8(a) economic rules. So, this could represent a shift towards more scrutiny on the EDWOSB program, similar to the 8(a) program.” (ibid)

Legislative Efforts to End the Program

The audit comes as some lawmakers seek to eliminate the Women-Owned Small Business program entirely.

In April, Sen. Mike Lee (R-Utah) and Rep. Glenn Grothman (R-Wis.) introduced the Ending Discrimination in Government Contracting Act. The legislation would eliminate contracting preferences for women-owned and socially and economically disadvantaged businesses. (ibid)

Neither bill has advanced beyond committee review. (ibid)

Don’t Miss This Step: FCP Now Requires T&C File Updates for Onboarding

FCP Update: T&C File Now Required in First Steps

Starting April 6, 2026, you must update your Terms & Conditions (T&C) file as part of the FCP First Steps onboarding process. FCP now integrates this long-standing MAS requirement directly into onboarding. (buy.gsa.gov March 31,2026)

You must update your T&C file if you:

  • Are a new contractor (awarded after August 28, 2025) and have not created an initial T&C file in FCP
  • Are a new FCP user and need to establish or update your T&C file
  • Are an existing FCP user adding a new catalog offering that requires a baseline action (e.g., adding services after offering only products) (ibid)

How to check:
Log in to catalog.gsa.gov and look for the “Update T&C” requirement in the First Steps banner on your Catalog Overview page.(ibid)

How to prepare your file:

  • Existing contractors: Download your current file from GSA eLibrary and remove all pricing and catalog details included in your Product File or Services Plus File (ibid)
  • New contractors: Follow I-FSS-600 requirements. Do not include pricing unless specifically required for certain SINs (ibid)

Who is not impacted:

  • Contractors awarded after August 28, 2025 who have already uploaded a T&C file (ibid)
  • Contractors who transitioned to FCP before this requirement (ibid)

Resources:
Terms & Conditions FAQ: https://catalog.gsa.gov/help#tnc
Getting Started Guide: Available in FCP for step-by-step onboarding instructions

Do you have questions or need assistance updating your T&C file? Give us a call.

Time is ticking to get your FAS ID

GSA recently shared that they will transition to FAS ID for login as part of a system update scheduled for April 14, 2026.

Here’s what to expect:
You will receive a separate email from Okta (sent from no*****@**ta.com or MFA-No-Reply+no*****@*sa.gov) during the week of April 6. This email will include instructions to complete your FAS ID registration before the April 14 transition.(assist.gsa.gov April 6 2026) After you click the activation link, you will:

  • Create a password
  • Set up a security question and answer

Once you complete these steps, your FAS ID credentials will be ready to use on April 14.(ibid)

👉 Please note that the registration link expires after 7 days, so please act promptly.

👉 If you do not receive the email, please check your junk or spam folder.

GSA considers this timeline tentative and will notify you by email if anything changes. (ibid)

Should you have any questions, feel free to give us a call.

General Services Administration rethinks federal acquisitions as AI reshapes contracting

The General Services Administration is overhauling the Federal Acquisition Regulation (FAR) while addressing how artificial intelligence is reshaping federal procurement, according to senior procurement executive Jeffrey Koses.(MeriTalk February 6, 2026)

GSA has launched nearly two dozen OneGov agreements since April to streamline federal IT acquisitions with standardized terms and pricing. Many agreements include AI tools from companies such as Anthropic, OpenAI, Google, Microsoft, Meta, xAI, and Perplexity.(ibid)

As GSA expands these agreements, the agency is evaluating how AI is changing solicitation design, proposal development, and evaluation. Officials are assessing how to operate effectively, leverage AI’s potential, and update terms and conditions for vendors.(ibid)

Koses warned that AI introduces risks to acquisition integrity, including an increase in protests and filings that use AI-generated content with fabricated citations. GSA is working to prevent procurement from becoming a contest of “who can write the best prompt” and is redesigning solicitation strategies, evaluation methods, and timelines as AI lowers proposal costs and expands the pool of bidders. (ibid)

GSA aims to preserve fairness and confidence in outcomes while accelerating procurement timelines to meet mission needs. Officials acknowledge that questions remain about AI’s long-term impact on acquisitions. (ibid)

The OneGov initiative remains in its early stages, focusing first on software, AI, and emerging technologies. Federal Acquisition Service experts partner with original equipment manufacturers to understand tools and bring offerings to market quickly. Looking ahead, GSA plans to standardize AI-specific terms and conditions to support OneGov agreements over the long term. (ibid)

Do you have questions as AI reshapes federal acquisition and contracting? Give us a call.

Advance Notice: MAS Refresh 31 and Upcoming Mass Modification

GSA’s Federal Acquisition Service (FAS) plans to release Multiple Award Schedule (MAS) Solicitation 47QSMD20R0001 – Refresh 31 in February 2026. This refresh introduces several important updates that will affect MAS contractors. (BUY.GSA.GOV 1/12/26)

After GSA issues Refresh 31, contractors must accept the related Mass Modification within 90 days. (ibid)


What’s Changing Overall

GSA will update the General Information section across MAS solicitations to:

  • Add new requirements for Artificial Intelligence (AI) systems and services, aligning with federal executive orders and OMB guidance.
  • Update proposal instructions that apply to all offerors.
  • Expand Transactional Data Reporting (TDR) to all remaining service SINs and make TDR mandatory for all MAS SINs.
  • Limit the Startup Springboard Program to vendors that qualify for FASt Lane.
  • Clarify that foreign replica weapons and inert ordnance are excluded from the MAS Program.
  • Update clauses and provisions to align with:
    • TDR requirements
    • Request for Offer (RFO) changes
    • Federal Acquisition Circular (FAC) 2025-06
  • Update subcontracting templates to reflect recent FAR changes. (ibid)

Important Change to Open Market Items

GSA has changed how contractors include open market items under MAS.

  • The previous flexible approach no longer applies.
  • Contractors must now use the Order-Level Materials (OLM) SIN and follow specific OLM rules.

GSA strongly recommends accepting the Mass Modification to add the OLM SIN if you do not already have it.

  • New MAS awardees will continue to receive a Mass Mod to add OLM.
  • Current contractors without the OLM SIN will receive a one-time Mass Modification to add it. (ibid)

Changes by Category

GSA will also revise instructions, templates, and descriptions for specific Large Categories, Subcategories, and SINs, including:

Office Management

  • Updates to office supplies and 3D printing SINs.

Human Capital

  • New and revised SINs covering human resources, talent acquisition, performance management, and retirement services.

Miscellaneous

  • Removal of subcategory limits for OLM instructions.

Professional Services

  • Updates to auditing, training, and workforce development SINs.

Transportation & Logistics

  • Revisions affecting vehicle services, package delivery, courier services, and equipment rentals.

Travel

  • Updates to employee relocation, lodging, and travel agency service SINs.(ibid)

Where to Learn More

For background on these changes and related resources, visit the RFO page on Acquisition.gov.


The MAS Refresh 31 and Upcoming Mass Modification includes many changes, need assistance or have a question, give us a call.