The circumstances under which a small business can still be considered “small” despite growth are incredibly complex.  Contractors should not expect that government contracting officers will always know the answer in a specific situation.  It is critical, therefore, that the companies themselves be prepared to help clarify size determinations and know when they can still be called small and when they cannot.  New SBA rules state that a company that originally qualified as a small business at the time of the original award of a Multiple Award Contract (MAC) can still be considered small if the MAC, itself, is set-aside for small businesses. Companies would not need to recertify for each task order unless required to do so by a contracting officer. Companies that originally qualified as small for a non-small business MAC, however, must recertify their status at the time of each task order IF the task order is set-aside for small businesses.  Confused yet?  The rules are still different for small businesses selling through GSA and VA FSS Multiple Award Schedule contracts.  Schedule contractors that originally qualified as small at the time of contract award can still consider themselves small until such time as their contract comes up for its next 5-year renewal option.  If the company is no longer small at that time, it will have to change its size status.  It can, however, continue to be classified as a small business before that time, unless a contracting officer asks for a size recertification on a specific task order.  Companies can also still be considered small under one NAIC’s number and not another.  While we apologize for making your head hurt on a Monday, it is obviously important that companies understand that they can be considered “small” or “other than small” depending on the circumstances of a specific acquisition.  Falsely certifying can lead to considerable legal costs, a damaged reputation, and lost future business.