SBA administers the 8(a) program, which includes determining whether it will accept requirements into the 8(a) program. Agencies must submit an offer letter to SBA identifying the requirement as well as any procurement history for the requirement, the estimated dollar amount, and, if the award is sole-source, the name of the particular 8(a) firm. SBA requires that agencies keep follow-on acquisitions in the 8(a) program until SBA releases them from the program. Our prior work—going back to 2006—has found that contracting officials have turned to tribal 8(a) firms as a quick, easy, and legal method of awarding contracts for any value, but that these benefits are not without oversight challenges for SBA, which is responsible for managing 8(a) firms’ participation in the program. For example, in January 2012, we found that SBA lacked the data and insight to enforce some of the new requirements put in place to ensure that tribal 8(a) firms do not operate in the program in perpetuity. We made a number of recommendations to improve oversight of tribal 8(a) firms, such as ensuring that a new SBA 8(a) database has the capability to track information on 8(a) contracts to help ensure SBA officials have the information necessary to enforce the 8(a) program regulations. SBA has taken some actions to address these recommendations, but some have not yet been addressed. In March 2016, we found that SBA’s oversight of tribal 8(a) firm’s participation in the 8(a) program continued to be a challenge and made several recommendations to help improve its oversight strategy. Our prior reports have also found that the number of sole-source 8(a) awards over $20 million at DOD overall has significantly declined over time—from 50 in 2008 to 4 in 2013. In December 2012, we reported that there was confusion regarding the requirements of the 8(a) justification. We recommended that the Administrator of the Office of Federal Procurement Policy (OFPP) promulgate guidance to clarify circumstances in which an 8(a) justification is required. OFPP, as chair of the FAR council which oversees changes to the acquisition regulations, is in the process of changing the regulations to address our recommendation. From fiscal years 2006 through 2015, the number of sole-source 8(a) contract awards over $20 million at DOD started to decline in 2011 and remained low through 2015, while the number of competitive contract awards over $20 million increased in recent years. Consistent with findings from our past reports, we found that sole-source awards generally declined in both number and value since 2011, when the 8(a) justification requirement went into effect. DOD awarded 22 of these contracts from fiscal years 2011 through 2015, compared to 163 such contracts in the prior 5-year period (fiscal years 2006 through 2010). The most common products and services acquired through 8(a) contracts over $20 million—under both competed and sole-source contracts—are construction, facilities support services, and engineering services. Figure 1 shows the decline in sole-source 8(a) contracts over $20 million and trends in competitively awarded 8(a) contracts of the same size. Pursuant to the mandate, we reviewed DOD’s March 2015 report to Congress and found that DOD reported a different number of sole-source 8(a) contract awards over $20 million than what we found in fiscal years 2011 through 2013. DOD reported awarding 23 such contracts in fiscal year 2011, 8 in 2012, and 5 in 2013, while we identified 13, 3, and 4 such contracts in those fiscal years, respectively. Consistent with our findings, DOD found no sole-source 8(a) contracts over $20 million awarded in fiscal year 2014 and a general decline in such contract awards since 2011. Based on our analysis of DOD’s report and discussions with the official responsible for the report, the differences are due to DOD’s inclusion of individual task or delivery orders in its count of sole-source 8(a) contracts. We did not include individual task or delivery orders in our numbers because they are not subject to the 8(a) justification. We found that DOD awarded two sole-source 8(a) contracts over $20 million with a total value of over $87 million in fiscal year 2015, one of which did not complete the 8(a) justification as required. In both cases, the contracting officers explained that they used sole-source 8(a) contracts because they were pressed for time. In one case, a Marine Corps contracting officer awarded a $24 million sole-source 8(a) contract for vehicle maintenance and repair to the incumbent contractor. However, the contracting officer did not complete an 8(a) justification as required. This contracting officer told us that the previous contracting officer for the requirement had retired without warning and there was limited time to award the follow-on contract. The contract went through several levels of review, including general counsel, and no one realized that a justification was required. She explained she had very limited experience awarding 8(a) contracts and was not aware of the required 8(a) justification. In fact, our analysis of FPDS-NG data showed that this office had not awarded any other sole-source 8(a) contracts over $20 million since fiscal year 2006. We did not pursue this issue because the contracting officer recognized that more training was needed and noted that the director of her office was developing training to address this issue. She further noted that there will not be a follow-on contract for this particular requirement, as the service is no longer needed. In the other case, Army officials said that they had a limited amount of time to ensure continuity of an engineering services contract for $63 million after a contract awarded through full and open competition was protested twice by the previous vendor. Contracting staff said that a sole-source 8(a) contract, which was not awarded to the previous vendor, was the only way to meet the requirement without a gap in services. Officials explained that they decided to shorten the period of performance on the sole-source contract from 5 years to 3 years and that the follow-on contract will be competed among 8(a) firms. Our analysis of the period of performance for sole-source and competitive 8(a) contracts over $20 million from fiscal years 2006 through 2015 showed that the average length of sole-source contracts has declined since 2012, while the average length of competitive contracts has remained more consistent over the time period. In fiscal year 2006, the average period of performance for a sole-source 8(a) contract was 4.8 years, yet starting in 2012 the average period of performance—which was 3.7 years—began to decline. By fiscal year 2015, the average period of performance was 2.1 years. For competed contracts 8(a) over $20 million, the contract length has consistently averaged between 4 and 5 years since 2007. Since 2011, tribal 8(a) firms have won an increasing number of competitively awarded 8(a) contracts over $20 million at DOD. Although these firms represent less than 10 percent of the overall pool of 8(a) contractors, the number of competitively awarded DOD 8(a) contracts over $20 million to tribal 8(a) firms grew from 26 in fiscal year 2011—or 20 percent—to 48 contracts in fiscal year 2015—or 32 percent of the total. In addition, since 2011, tribal 8(a) firms have consistently won higher value awards than other 8(a) firms for competitive 8(a) contracts over $20 million. In fiscal year 2015, the average award size of a competed 8(a) contract to a tribal 8(a) firm was $98 million, while other 8(a) firms had an average award size of $48 million. See appendix II for more data on awards to tribal versus other 8(a) firms. Contracting officials from the 14 offices in our review stated that there is, in general, a renewed agency-wide emphasis on competition. Whereas in the past they used sole-source 8(a) contracts to quickly, easily, and legally meet agency needs—as we have previously reported—officials explained that awarding large sole-source 8(a) contracts is less palatable in the current environment. Our review of 9 sole-source 8(a) contracts and their follow-on procurements supported this view. Five of the 9 sole- source 8(a) contracts we reviewed were competed in the follow-on contracts, and, for most of the remaining 4 contracts with follow-on sole- source contracts, officials stated that they plan to competitively award future procurements or are already in the process of doing so. In addition, DOD officials from almost half of the offices noted that a decline in their budgets or a decline in the size of their requirements rendered the 8(a) justification not applicable because most of their contracts fall below the $20 million threshold. Finally, DOD officials had varying opinions about whether the 8(a) justification was a deterrent to awarding large sole- source 8(a) contracts. Some noted that the 8(a) justification review process would deter them, while others said they would award a sole- source contract over $20 million if they found that only one vendor could meet the requirement. DOD officials we spoke with said that they prefer to compete high-dollar awards and reported a renewed agency-wide emphasis on competition, which steered them away from awarding large sole-source 8(a) contracts. Our prior work has found that agencies liked to use the unique provisions of tribal 8(a) contracting because they could quickly, easily, and legally award contracts to meet agency needs.