CR-001
May 14, 2026
HUBZone redesignation cycle and Redesignated Area grace period
Article:
HUBZone Redesignated Areas Expire July 1, 2026: What HUBZone-Certified Firms Need to Know
What changed:
We had described the HUBZone redesignation as running on a 5-year cycle anchored to July 2021. The actual rule is a 3-year grace period for Redesignated Areas anchored to July 2023, which is why these areas expire July 1, 2026.
Before
“HUBZone designations run on a 5-year cycle. Areas redesignated in July 2021 carry through to 2026.”
After
13 CFR 126.103 defines a Redesignated Area as one that previously qualified as a HUBZone but has since lost qualification. Redesignated Areas carry a 3-year grace period from the date SBA published the most recent Designations Map (July 1, 2023), which is why those areas expire July 1, 2026.
Primary source
13 CFR 126.103
Why it matters:
A HUBZone-certified small business planning its principal-office strategy on a 5-year cycle would miss the July 2026 cliff by two full years.
CR-002
May 14, 2026
SBA receipts-based size standard averaging window and current dollar caps
Article:
NAICS Code for IT Services: How to Pick Yours
What changed:
We had stated SBA size standards use a 3-year receipts average and listed an outdated $16.5M cap for IT services NAICS codes. SBA moved to a 5-year averaging window in 2022, and the current cap for 541618 and 541690 is $19.0M.
Before
“SBA size standards average your last 3 years of receipts. The cap for NAICS 541618 / 541690 is $16.5M.”
After
13 CFR 121.104 requires receipts averaging over the past 5 completed fiscal years (raised from 3 years by the Runway Extension Act). The current receipts-based cap for NAICS 541618 (Other Management Consulting Services) and 541690 (Other Scientific and Technical Consulting Services) is $19.0M per 13 CFR 121.201.
Primary source
13 CFR 121.104 and 13 CFR 121.201
Why it matters:
A small business straddling the threshold could miss critical bidding eligibility, or wrongly certify itself as small, using the outdated 3-year window or the outdated $16.5M cap.
CR-003
May 14, 2026
CMMC rollout phase sequencing (Phase 2 vs Phase 3 level mapping)
Article:
CMMC Phase 2 Deadline November 2026: What Small DIB Contractors Need to Know
What changed:
Earlier drafts inverted CMMC Phase 2 and Phase 3, describing Phase 2 as Level 3 and Phase 3 as Level 2. The DoD rollout sequence is Phase 2 = Level 2 self-assessment / C3PAO-assessed deadlines, Phase 3 = Level 3 deadlines.
Before
“Phase 2 (November 2026) covers Level 3 contracts; Phase 3 covers Level 2.”
After
Per 32 CFR Part 170 and DoD's phased rollout, Phase 2 covers Level 2 (self-assessment and C3PAO-assessed contracts). Phase 3, beginning the following year, covers Level 3.
Primary source
32 CFR Part 170
Why it matters:
A defense contractor planning compliance budget against the wrong phase order would either over-invest a year early or arrive at the November 2026 cutoff without an assessment in hand.
CR-004
May 14, 2026
GAO bid protest jurisdiction citation and CICA automatic stay
Article:
Bid Protest Sustain Rate vs. Effectiveness Rate: 16% vs. 52%
What changed:
We had cited FAR 33.103 as the GAO bid protest framework. FAR 33.103 governs agency-level protests; GAO's own protest rules live in 4 CFR Part 21. Separately, we had not anchored the 5-day automatic-stay window to its CICA source.
Before
“GAO bid protests are governed by FAR 33.103.”
After
GAO bid protests are governed by 4 CFR 21.2(a)(2) (GAO's own bid protest regulations). The 5-day window to trigger an automatic stay of contract performance comes from 31 U.S.C. 3553(d)(4)(A) (CICA).
Primary source
4 CFR 21.2(a)(2) and 31 U.S.C. 3553(d)(4)(A)
Why it matters:
A first-time protester reading the wrong rule wouldn't find the actual GAO protest deadlines or the statutory basis for the automatic stay.
CR-005
May 14, 2026
Rule of Two framing: "automatic" vs "presumed" set-aside
Article:
Rule of Two Set-Asides: When Contracting Officers Must Act
What changed:
Earlier drafts described below-Simplified-Acquisition-Threshold acquisitions as "automatically reserved" for small businesses. The Rule of Two is a presumption with documented contracting-officer judgment, not an automatic set-aside.
Before
“Acquisitions below the Simplified Acquisition Threshold are automatically reserved for small businesses.”
After
Per FAR 19.502-2(a), acquisitions above the micro-purchase threshold and at or below the Simplified Acquisition Threshold are reserved exclusively for small business concerns, unless the contracting officer determines there is no reasonable expectation of obtaining offers from two or more responsible small business concerns at fair market prices. The set-aside is a presumption, not automatic.
Primary source
FAR 19.502-2(a)
Why it matters:
A small business assuming an automatic set-aside would not prepare its pre-award case to defend the set-aside against a contracting officer's "not enough small business interest" determination.
CR-006
May 14, 2026
Veteran-owned business certification authority after the 2023 transfer
Article:
VOSB vs SDVOSB: Which One Do You Need?
What changed:
Earlier drafts described VA CVE certification (legacy program) as the path for VOSBs and a separate SBA process for SDVOSBs. Since January 1, 2023, both VOSB and SDVOSB are certified by SBA's Veteran Small Business Certification program (VetCert). The remaining difference is set-aside scope, not certifying body.
Before
“VOSBs certify through VA CVE; SDVOSBs certify separately through SBA.”
After
Effective January 1, 2023, both VOSB and SDVOSB are certified by the SBA Veteran Small Business Certification program under 13 CFR Part 128. The difference between VOSB and SDVOSB is the set-aside scope (SDVOSB is required for VA-issued SDVOSB set-asides; both qualify for VA VOSB set-asides), not the certifying body.
Primary source
13 CFR Part 128
Why it matters:
Veteran-owned businesses navigating dual-certification under the assumption of two separate processes would waste months chasing a program (VA CVE) that no longer exists.
CR-007
May 14, 2026
FAR Part 19 restructuring described as final when it was proposed; fabricated section number
Article:
The FAR Part 19 Overhaul: What Changed for Small Businesses
What changed:
Earlier drafts described the September 2025 FAR Part 19 restructuring (rename to "Small Business," new lifecycle subparts 19.1, 19.2, 19.3) as if already final. The restructuring is at the proposed-rule stage. The article also cited "FAR 19.104-1," which does not exist in the current FAR.
Before
“Under FAR 19.104-1, the new Subpart 19.1 covers...”
After
The September 2025 FAR Part 19 restructuring (FAR Case 2024-XXX, proposed rule) would rename Part 19 to "Small Business" and reorganize provisions into lifecycle subparts. The proposed rule is not yet final. Current FAR Part 19 remains the controlling text; FAR 19.104-1 is not a current section.
Primary source
FAR Part 19 (current); Federal Register proposed rule notice (FAR Case 2024-XXX).
Why it matters:
A newcomer trying to verify a set-aside rule against acquisition.gov would hit a 404 on a fabricated section number and lose trust in everything else on the site.
CR-008
May 14, 2026
FAR 42.709 penalty structure inverted: default is 1x, not 2x
Article:
Indirect Cost Rates for Government Contracting
What changed:
Earlier drafts described the FAR 42.709 penalty for unallowable indirect costs as 2x by default. The actual rule under FAR 42.709-2 is 1x for the first occurrence; the 2x penalty applies only when the cost was previously determined to be unallowable in writing.
Before
“Including unallowable costs in your indirect rate proposal triggers a 2x penalty.”
After
Per FAR 42.709-2(a), the penalty for unallowable indirect costs is the amount of the unallowable cost (1x). The 2x penalty under FAR 42.709-2(b) applies only when the same cost was previously determined to be unallowable in writing in a prior audit, claim, or proposal.
Primary source
FAR 42.709-2
Why it matters:
Doubling the perceived penalty could scare a small business out of indirect-rate proposals entirely, when the actual first-occurrence exposure is half what the article implied.
CR-009
May 14, 2026
WOSB sole-source authority described as EDWOSB-only
Article:
WOSB Certification: How to Get Certified as a Women-Owned Small Business
What changed:
Earlier drafts (across four articles) stated that sole-source contract authority under the WOSB program is available only to Economically Disadvantaged WOSBs (EDWOSB). The actual rule (FAR 19.1506) makes sole-source available to both WOSB and EDWOSB firms. The programs differ in NAICS code scope, not in sole-source availability.
Before
“Only EDWOSB firms can receive WOSB sole-source contracts.”
After
Per FAR 19.1506 and 13 CFR 127.503, both WOSB and EDWOSB firms are eligible for sole-source awards in their respective NAICS code lists. The WOSB program list contains roughly 626 NAICS codes; the EDWOSB list contains roughly 733. Sole-source availability is not restricted to EDWOSB.
Primary source
FAR 19.1506; 13 CFR 127.503
Why it matters:
A WOSB-only firm reading the old framing would miss a sole-source path they actually qualify for.
CR-010
May 14, 2026
DoD-only NDAA J&A threshold applied as FAR-wide; fabricated approval-tier table
Article:
Sole-Source Contracts in Government Contracting
What changed:
Earlier drafts applied the DoD-only NDAA Section 1804 / 10 USC 3204 threshold change (J&A approval thresholds $10M to $100M) to the FAR-wide sole-source approval ladder under FAR 6.304. The article also presented a "$100M / $500M" tier table that does not appear in the source rule.
Before
“Justification and approval thresholds: $10M department-level, $100M agency head...”
After
FAR 6.304 establishes the J&A approval ladder for all federal contracts. The DoD-specific NDAA Section 1804 amendment to 10 USC 3204 raised DoD thresholds; civilian agencies operate under 41 USC 3304, which has different threshold structures. The approval tiers depend on which agency is contracting.
Primary source
FAR 6.304; 10 USC 3204 (DoD); 41 USC 3304 (civilian)
Why it matters:
A civilian-agency contractor reading the DoD-only framing would misjudge protest exposure on a sole-source action.
CR-011
May 14, 2026
Fabricated effective date for 5-year receipts averaging
Article:
SBA Size Standards Explained
What changed:
Earlier drafts cited "13 CFR 121.104: Revenue calculation (effective December 17, 2024)" as the source for mandatory 5-year revenue averaging. That effective date is wrong. Mandatory 5-year averaging traces to the Runway Extension Act of 2018 (Public Law 115-324) and SBA's December 5, 2019 final rule (84 FR 66561), with the mandatory transition completing January 6, 2022.
Before
“SBA moved to 5-year revenue averaging effective December 17, 2024.”
After
Per the Runway Extension Act (Public Law 115-324, December 17, 2018) and SBA's December 5, 2019 final rule (84 FR 66561), the 5-year averaging window became mandatory at the end of the transition period on January 6, 2022. 13 CFR 121.104 is the implementing regulation.
Primary source
13 CFR 121.104; Public Law 115-324; SBA final rule 84 FR 66561
Why it matters:
A firm at the size threshold making recertification timing decisions based on a wrong effective date would miscalculate the year their averaging window switched.
CR-012
May 14, 2026
STTR participating agency count and prior-cycle award ceilings
Article:
SBIR and STTR Programs for Small Businesses
What changed:
Earlier drafts listed 6 STTR participating agencies including USDA. The authoritative count per sba.gov is 5 agencies. The article also cited Phase I and Phase II award ceilings ($314,363 / $2,095,748) that were prior-cycle figures. The current ceilings per sbir.gov October 2024 guidelines are $323,090 / $2,153,927.
Before
“STTR includes 6 participating agencies: DoD, NIH, NSF, DOE, NASA, and USDA. Phase I awards cap at $314,363; Phase II at $2,095,748.”
After
STTR includes 5 participating agencies: DoD, NIH, NSF, DOE, and NASA (USDA participates in SBIR, not STTR). Per sbir.gov October 2024 award guidelines, Phase I awards cap at $323,090; Phase II at $2,153,927. These ceilings are reset annually.
Primary source
sba.gov SBIR/STTR program page; sbir.gov FY2025 award guidelines
Why it matters:
A newcomer applying to a USDA STTR program would waste weeks chasing a program that does not exist. Budget figures keyed to prior-cycle ceilings would understate available award size.