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FAR Part 19 Overhaul: Navigating the New Landscape for 8(a) Government Contracts
The Federal Acquisition Regulatory (FAR) Council released the FAR Part 19 model deviation text on September 26, 2025, ushering in a significant reorganization of the rules governing small business set-aside contracts. This updated structure streamlines the layout to align with the acquisition lifecycle and introduces key revisions, particularly impacting the Small Business Administration’s (SBA) 8(a) Business Development Program.
The two most notable changes introduced by the revised FAR Part 19 focus on follow-on flexibility and increased competition.
Dismantling the “Once 8(a), Always 8(a)” Rule
The FAR Council’s revisions effectively dismantle the longstanding “Once 8(a), Always 8(a)” rule. Historically, a requirement accepted into the 8(a) Program had to remain there for follow-on contracts unless the SBA agreed to its release. This rule reinforced the SBA’s significant oversight role.
Now, the landscape has changed. Contracting officers possess new authority—without needing SBA approval—to release follow-on 8(a) contracts from the program if that follow-on is set aside under the HUBZone, SDVOSB (Service-Disabled Veteran-Owned Small Business), or WOSB (Women-Owned Small Business) programs.
This new exception limits the SBA’s authority, removing its control over certain follow-on contract decisions. It grants contracting officers greater discretion in meeting their agency’s needs and contracting goals. Furthermore, the requirement to provide written notice to the SBA has also been eliminated when utilizing a mandatory source or when transitioning the requirement to one of the permitted set-aside programs.
However, if there is no mandatory source and the follow-on contract will not be set-aside for HUBZone, SDVOSB, or WOSB firms, SBA approval is still necessary.
Encouraging Competition through GWACs
The second major reform in the new FAR Part 19 signifies a clear shift toward prioritizing competition over sole-source awards, especially through government-wide acquisition contracts (GWACs). This change aligns with the Administration’s broader goal of consolidating contracting across agencies to achieve faster, more efficient, and more cost-effective acquisitions.
The new FAR establishes that contracting officers must first attempt to conduct competition for procurements that fall below the competitive thresholds by competing 8(a) orders using GWACs. Sole-source awards may only be pursued if competition is determined to be not feasible.
The competitive thresholds referenced in the new FAR are $8.5 million for manufacturing and $5.5 million for other industries, effective October 1, 2025.
Implementation and Next Steps
While these changes are substantial, the new FAR’s model deviation text is not yet codified. It currently conflicts with the SBA’s existing regulations, though the SBA is expected to revise its rules to align with the new FAR framework.
For now, the new framework only applies where specific agencies adopt the deviation. The General Services Administration, the Securities and Exchange Commission, and the Commodity Futures Trading Commission have already issued deviations adopting the new language of FAR Part 19, and others are anticipated to follow suit.
Key Takeaways: The changes expand contracting opportunities across programs by allowing follow-on 8(a) contracts to transition into other socioeconomic set-asides (HUBZone, SDVOSB, or WOSB) without requiring SBA approval. Furthermore, contracting officers must now prioritize competition for 8(a) procurements below the competitive thresholds, especially when utilizing GWACs.
Tags: FAR Part 19, 8(a) Program, Government Contracting, Small Business, Follow-On Contracts, Set-Aside Contracts, HUBZone, SDVOSB, WOSB, GWACs, Competition, Sole-Source Awards, marketus