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Bass Berry & Sims – Generally, when a business is awarded a multi-year IDIQ contract, it retains its “small” business designation unless a contracting officer requires the business to recertify its size status, and has since grown larger than the small business threshold. A recent decision from the Small Business Administration’s Office of Hearings and Appeals throws a wrench into that general understanding when OHA found an implicit recertification requirement absent an express requirement or CO demand.
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