SBA recently issued new guidance on how to demonstrate social disadvantage–one of the elements an individual must meet to be eligible for SBA’s illustrious 8(a) Business Development Program. The guidance implements a streamlined social disadvantage narrative format–limiting the number of social disadvantage instances to two and asking only for direct answers to six questions for each instance. The “new” format really just hones in on the elements SBA has always asked for 8(a) social disadvantage narratives to demonstrate, substantively, not changing a thing. Nevertheless, SBA has been quite firm in requiring this new, short and sweet, structured format–so let’s dig into it a bit.
Since the federal court’s decision in Ultima (you can read all about here), the 8(a) Program has been swept up in a whirlwind of change. The whole application process was paused and un-paused. Awards were postponed. The vast majority of active, individual 8(a) participants had to submit social disadvantage narratives (some, in just a few days). And naturally, there was a massive influx in social disadvantage narratives requiring SBA’s review: some needing immediate review for 8(a) awards; and all hoping for prompt review to avoid any 8(a) Program term pause or termination.
Here at SmallGovCon, this inspired our 8(a) landing page, the 8(a) Contractors’ Toolkit (for all the recent 8(a) happenings and updates you might’ve missed). Over at SBA, it inspired steps to maximize the 8(a) Program’s review capacity and efficiency. For one, SBA rallied the troops–dramatically increasing its fleet of 8(a) eligibility reviewers. It also issued this new guidance simplifying the narrative format–hoping to streamline reviews.
The guidance changes the narrative format in two primary ways:
- it directs drafters to focus on just two instances of social disadvantage; and
- it asks them to directly and succinctly (and to only) answer six specific questions for each instance…
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