The Jan. 16, 2026, announcement by Secretary of War Pete Hegseth that “every small business, sole source, 8(a) contract that is over $20 million” will undergo a “line by line review” raises significant questions and considerations for all government contractors that participate in 8(a) program activities. For example, 8(a) participants that are currently performing – or that recently performed – set-aside or sole-source awards may want to consider developing a complete picture of their program-based portfolio, including awarding agency, contract value, period of performance, applicable small-business and socioeconomic requirements, and any recertification obligations. As part of that analysis, 8(a) participants may want to further assess where on the risk spectrum the company’s participation may sit and, if appropriate, prioritize review readiness.
Read on to learn more about how the policy developed over the past seven months and other considerations for contractors.