Since my requirement was solicited as a competitive 8(a) requirement, do I still need to take into consideration the potential awardee's small business size status for the NAICS, or am I only concerned that they are in fact an eligible 8(a) program participant (i.e., can I award to an 8(a) vendor despite large business status under NAICS Code)?
The Small Business Administration Guide to Size Standards and FAR 19.303 states that the Contracting Officer shall determine the appropriate NAICS codes and related small business size standard and include them in the solicitations above the micro-purchase threshold. The guide provides the following information and paragraph 2 states that the contractor must meet the size standard for each individual contract. I would also recommend that you contact your small business office to discuss your specific contract prior to award.
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USE OF SIZE STANDARDS FOR GOVERNMENT PROCUREMENT
The contracting officer will designate, as part of the solicitation, the applicable size standard for the government procurement. The size standard is based on the industry classification of the goods or services being procured. The proper NAICS industry is that which best describes the principal purpose of the procurement, considering the industry description in NAICS. When more than one NAICS is involved in a contract, consideration is to be given to the function of the goods and services being purchased and the relative value and importance of each. To bid on Federal contracts, the concern must self-certify in ORCA (and above) that it is a small business under the appropriate size standard set forth in the solicitation. The size of the concern at the time of self-certification prevails for that contract. A concern may grow above the size standard before or after award without loss of eligibility to perform on that contract.
In the 8(a), HUBZone and SDB Programs, the concern must meet the size standard for its primary industry to be admitted to the program. Then it must meet the size standard for the NAICS industry assigned to each individual contract. If a procurement calls for two or more items with different size standards and the offeror must bid on all end items, it may qualify as a small business if it meets the common size standard for those items accounting for the greatest percentage of total contract value. If the offeror is not required to bid on all items, it may bid only on items for which it meets the size standard. To be awarded a Government small business set-aside or 8(a) contract, the concern must perform at least a given percentage of the contract. This provision limits the amount of subcontracting a concern may enter into with other firms when performing these types of contracts.