Set-aside codes on SAM.gov contract notices: what SBA, 8A, HZC, WOSB and the others mean

The contracting officer. FAR 19.501(b) says the contracting officer makes the determination to make a small business set-aside, in total or in part, and that an SBA procurement center representative may make a recommendation. Among the programs, FAR 19.203 says there is no order of precedence among the 8(a), HUBZone, service-disabled veteran-owned and women-owned programs, and that in choosing among them the contracting officer should consider, at a minimum, the results of market research and the agency's progress toward its small business goals.

Sources sought notices explains one way an agency does that market research. A label on a notice is a decision a person made about that purchase, not a fact about the business that reads it.

A contract notice has a set-aside field. In SAM.gov's data the field holds a short code with a description beside it: GSA's document for the Get Opportunities public API lists a set-aside description and a set-aside code among the fields of each notice it returns, and a table of valid set-aside values, eighteen codes in all. The document says only one set-aside value is accepted in the field at this time.

The sections below take the codes in groups, in the table's order, with the part of the FAR the table names for each. Those are the codified FAR's numbers. The FAR overhaul text that acquisition.gov also publishes numbers Part 19 differently, for example 19.104-1 for total small business set-asides and 19.108 for the 8(a) program.

The descriptions are GSA's words for its data. The words on a notice as SAM.gov shows it may be worded differently, so the notice itself is the text that counts. The document's change log lists the set-aside code being added and its values updated in the document's early versions, and no later change to them.

SBA is a total small business set-aside and SBP a partial small business set-aside, both under FAR 19.5. The code SBA stands for the total set-aside, not for the Small Business Administration, the agency that shares its letters.

In a total set-aside the acquisition is limited to small business concerns (FAR 19.501(a)(1) and 19.502-2). In a partial set-aside the contracting officer sets aside a portion or portions of an acquisition for exclusive small business participation, and the solicitation identifies which portions are set aside and which are not (FAR 19.502-3). FAR 19.501(e) adds that a solicitation involving a set-aside, in total or in part, specifies the NAICS codes and the size standards that go with them. PSC and NAICS codes explains the codes.

8A is an 8(a) set-aside and 8AN an 8(a) sole source, both under FAR 19.8. Section 8(a) of the Small Business Act lets SBA enter into contracts with other agencies and award subcontracts for performing them to participating firms, and FAR 19.800(b) says contracts may be awarded to SBA for performance by 8(a) participants on either a sole source or a competitive basis.

A set-aside here is competition limited to 8(a) participants, and a sole source award is the other basis FAR 19.800 names; FAR 19.805-1 says when an acquisition offered to SBA is competed and when SBA may accept it as a sole source award. SBA's 8(a) Business Development program explains the program.

HZC is a HUBZone set-aside and HZS a HUBZone sole source (FAR 19.13). SDVOSBC is a service-disabled veteran-owned small business set-aside and SDVOSBS a sole source (FAR 19.14). The first code in each pair limits competition to businesses in the program: FAR 19.1305 and 19.1405 let the contracting officer set an acquisition aside for competition restricted to HUBZone small business concerns, or to service-disabled veteran-owned small business concerns, when the officer reasonably expects offers from two or more of them and an award at a fair market price.

The second code is the sole source route. FAR 19.1306 and 19.1406 list the conditions for considering a sole source award in each program, and one of them is that the contracting officer does not reasonably expect offers from two or more businesses in it. FAR 19.1403 says SBA determines status as a service-disabled veteran-owned small business concern, under its own rules. SBA's HUBZone program and SBA's veteran-owned small business program explain the programs.

WOSB is a Women-Owned Small Business Program set-aside and WOSBSS a WOSB Program sole source. EDWOSB is an economically disadvantaged women-owned small business set-aside and EDWOSBSS an EDWOSB sole source. All four are under FAR 19.15.

FAR 19.1505 ties the set-asides to NAICS codes. A contracting officer may restrict competition to EDWOSB concerns for requirements in NAICS codes where SBA has determined that women-owned small businesses are underrepresented in federal procurement, and to WOSB concerns, EDWOSB concerns included, where SBA has determined they are substantially underrepresented. Either needs a reasonable expectation, based on market research, of offers from two or more such concerns at a fair and reasonable price.

FAR 19.1506 gives the sole source route, which is likewise tied to those NAICS codes, and FAR 19.1503 says SBA determines status under the program's rules. SBA's Women-Owned Small Business program explains the program.

LAS is a local area set-aside, under FAR 26.2. That subpart carries out the Stafford Act's preference for local organizations, firms and individuals when contracting for major disaster or emergency assistance activities (FAR 26.200). FAR 26.202-1 says the contracting officer may set aside solicitations to allow only local firms within a specific geographic area to compete, defines that area, which cannot go outside the declared major disaster or emergency area, and decides separately whether to restrict the set-aside further to small business concerns. So a local area set-aside is about where firms are, not about a program.

Five codes are specific to one agency in GSA's table. IEE, an Indian Economic Enterprise set-aside, and ISBEE, an Indian Small Business Economic Enterprise set-aside, are specific to the Department of the Interior. BICiv, a Buy Indian set-aside, is specific to the Indian Health Service in the Department of Health and Human Services. VSA, a veteran-owned small business set-aside, and VSS, a veteran-owned small business sole source, are specific to the Department of Veterans Affairs and are separate codes from SDVOSBC and SDVOSBS. The document gives these descriptions and no more: it does not say what each requires, so the notice and that agency's own rules are where an explanation would be.

It is the buyer's restriction. A label records which businesses the contracting officer limited the competition to or, on a sole source code, the program the award is considered under. It is not a finding about any business, and it does not settle whether a business is small, is in a program or may compete for the purchase.

The size answer and a business's status in a program are the owner's own matters, and SBA's rules for each program decide status. SBA's small business programs is the overview, with a guide each on 8(a), HUBZone, women-owned and veteran-owned businesses. Questions about size, ownership or affiliation are about your own facts: a free APEX Accelerator, SBDC or SCORE counselor, or an attorney, reads them with you, and the card just below this guide names where to ask.

On a contract notice, Firmenza shows the set-aside as published and says that who may compete under it is set by the notice and the rules it names, not by Firmenza. On a notice you saved, it reports a changed set-aside as a dated line. Contract opportunity matches in Firmenza goes through it, How to find federal contracts covers finding notices, and Federal contracts for any business covers where to start.