The D’Aniello Institute for Veterans and Military Families (IVMF) opposes the proposed expansion of SBA’s small business size standards. With over two decades of research and experience across the military-connected entrepreneurial ecosystem, the IVMF understands the importance of maintaining meaningful pathways for small and emerging firms to enter, compete, and grow in the federal marketplace. We also recognize that businesses graduating from small business status can face significant challenges as they transition to full and open competition. Those challenges deserve thoughtful policy solutions. Substantially expanding eligibility for federal small-business procurement programs, however, is not the appropriate mechanism for addressing the graduation cliff.

Doing so risks solving one problem by creating another. Substantially expanding size standards would require small and emerging businesses to compete within programs specifically designed for them against firms with significantly greater revenue, resources, contracting experience, and access to capital. For businesses seeking to secure their first federal contract or establish the past performance necessary to grow, expanding the pool of larger, more established competitors can make an already difficult path into the federal marketplace even harder.  Federal small-business programs should serve as an on-ramp to the federal marketplace and support a healthy pipeline of businesses that can enter, compete, grow and ultimately graduate into full and open competition.

At the same time, the policy debate should not be framed simply as a choice between small businesses and large corporations. Businesses that have outgrown small-business status occupy an important and often difficult position in the federal marketplace and face distinct challenges as they move into full and open competition. Rather than broadening the definition of “small” to include increasingly large firms, SBA and policymakers should pursue targeted solutions that support these businesses successfully through that transition while preserving meaningful procurement opportunities for small and emerging firms.

The IVMF opposes this rule because addressing the challenges faced by graduating businesses should not come at the expense of those still working to gain a foothold in the federal marketplace. If enacted as proposed, this rule would make it harder for new and emerging firms to compete for federal contracts, weakening the pipeline of small businesses the federal procurement system should be working to build.

IVMF’s Comment on FR Doc # 2026-17042 

Ray Toenniessen
Deputy Executive Director
D’Aniello Institute for Veterans and Military Families