Have received a question from a contractor competing for this contract in regards to whether their firm can subcontract the task The solicitation maintains a 100% set aside for small business. We have selected 12 contracting firms from NAICS search on VetBiz, SBA, and also SAMS. All Contract nominees check out. The complication and the reason for this question is one of these contractors has inquired as to whether the work can be subcontracted. I am writing to inquire about what FAR references would apply in addressing this issue.
Yes, work can be subcontracted under the regular 100% small business set-aside.
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Since your solicitation is a SB set-aside, you should have FAR clause 52.219-6. Look in your solicitation to see if you have FAR clauses 52.219-8 or 52.219-14. These 2 clauses (52.219-8 and 52.219-14), are not mandatory to be put in solicitations for SB set-asides under the SAT per FAR 19.508(e) and FAR 19.7-8 (a). However, if they are in your solicitation, then offerors will have to comply with that during performance of the contract. Again, there is nothing that fully restricts a contractor utilizing subcontractors in a 100% small business set-aside.
I cannot speak to VA specific regulations and policies though.