Comment on FR Doc # 2026-11765
Anonymous AnonymousOpposeIndividual
Summary: The commenter, a U.S. Army veteran and consultant for veteran-owned businesses, opposes the proposed rule because it replaces individualized evaluations of social disadvantage with a rigid evidentiary standard. They argue that the new requirement to prove specific, documented discrimination ignores systemic barriers and will unfairly exclude deserving small businesses from the 8(a) program.
I respectfully oppose the SBA's proposed rule amending the eligibility standards for the 8(a) Business Development Program.
As a U.S. Army veteran, I have dedicated my career to serving my country and helping other entrepreneurs succeed. Today, I work directly with veteran-owned businesses, providing training and one-on-one consulting on government contracting, certifications, and federal procurement opportunities. I have seen firsthand the value that the 8(a) Business Development Program brings to small businesses that have historically faced barriers to competing in the federal marketplace.
While I understand SBA's responsibility to comply with court decisions and constitutional requirements, I believe this proposed rule creates a new standard that is unnecessarily restrictive and inconsistent with the intent of Congress when it established the 8(a) Program.
The proposed rule would require applicants to prove they suffered material harm from specific government or private policies that discriminated against their racial, ethnic, or cultural group. This standard overlooks the reality that many barriers are cumulative, systemic, and difficult to trace to a single policy or documented event. Many entrepreneurs face unequal access to capital, contracting relationships, business networks, mentorship, and growth opportunities throughout their careers. Those obstacles are real even when they cannot be tied to one specific government action or court case.
The 8(a) Program was designed to help level the playing field, not guarantee contracts, but provide qualified businesses an opportunity to compete. Success in the program still requires hard work, performance, financial management, and the ability to deliver results. The proposed rule risks excluding deserving businesses by replacing an individualized evaluation with a rigid evidentiary standard that many legitimate applicants will be unable to satisfy.
As someone who advises veteran entrepreneurs every day, I am concerned this change will discourage participation, increase uncertainty, and create additional administrative burdens for small businesses already struggling to navigate the federal acquisition process.
I respectfully request that SBA reconsider this proposal and instead adopt an approach that:
* Preserves individualized evaluations of social disadvantage.
* Recognizes that disadvantage can result from cumulative experiences rather than a single documented discriminatory policy.
* Maintains constitutional compliance while preserving Congress's original purpose of expanding opportunities for disadvantaged small businesses.
* Ensures that qualified entrepreneurs are not excluded because they cannot produce evidence of a specific government or private policy that directly harmed them.
The 8(a) Business Development Program has helped thousands of businesses grow, create jobs, and contribute to the American economy. Any reforms should strengthen the program while preserving its mission of expanding opportunity for qualified small business owners.
Thank you for considering my comments.