FAR 19.1503—Status.
Plain-English Summary
FAR 19.1503 explains how a concern’s status is established and verified for Women-Owned Small Business (WOSB) and Economically Disadvantaged Women-Owned Small Business (EDWOSB) program purposes. It covers four main topics: SBA’s role in determining status under 13 CFR part 127, the contracting officer’s duty to verify SAM registration and certification before making a WOSB or EDWOSB set-aside or sole-source award, the consequences when SBA later issues an adverse eligibility decision, and the special rule for joint ventures seeking WOSB/EDWOSB treatment. In practice, this section is about making sure only properly certified firms receive WOSB/EDWOSB awards and that agencies stop relying on an award if SBA later finds the firm was not eligible. It also ties status verification to SAM and notes that pending certification applications appear in DSBS, not as proof of certified status in SAM. For contracting officers, the section creates a pre-award verification step and a post-award corrective-action obligation; for contractors, it underscores the need to maintain current certification and SAM information. For agencies, it affects award counting, reporting, and FPDS updates when SBA overturns eligibility.
Key Rules
SBA decides program status
Whether a concern qualifies as an EDWOSB or WOSB eligible under the WOSB Program is determined by SBA under 13 CFR part 127. Contracting officers and agencies do not make the final eligibility determination themselves.
Verify SAM before award
For a WOSB or EDWOSB set-aside or sole-source award, the contracting officer must confirm that the offeror is registered in SAM and is designated there as a certified EDWOSB or WOSB concern. Pending certification applications shown in DSBS are not the same as certified status in SAM.
Adverse SBA decision has consequences
If SBA issues a decision from a current eligibility examination finding the concern did not qualify, the contracting officer may terminate the contract and must not exercise options or award additional task or delivery orders. The agency also may not count the award toward WOSB/EDWOSB small business goals.
Update procurement records
When SBA makes a final adverse eligibility decision, agencies must update FPDS from the date of award to reflect that decision. This ensures procurement data and small business goal reporting are corrected.
Joint ventures can qualify
A joint venture may be treated as an EDWOSB or WOSB eligible under the program if the EDWOSB or WOSB participant is certified in SAM and the joint venture meets the requirements of 13 CFR 127.506. Joint venture eligibility is therefore conditional, not automatic.
Responsibilities
Small Business Administration (SBA)
Determine whether a concern qualifies as an EDWOSB or WOSB eligible under the WOSB Program, conduct eligibility examinations, and issue decisions under 13 CFR part 127 that control program status.
Contracting Officer
Before making a WOSB or EDWOSB set-aside or sole-source award, verify SAM registration and certified status; follow the set-aside procedures in 19.1505(d); and, if SBA later finds the concern ineligible, consider termination, stop exercising options, and stop awarding further task or delivery orders.
Agency
Do not count an award toward WOSB/EDWOSB small business goals after an adverse SBA eligibility decision, and update FPDS from the date of award to reflect the final SBA decision.
Offeror / WOSB or EDWOSB Concern
Maintain SAM registration and certified status in SAM when seeking WOSB or EDWOSB set-aside or sole-source awards; understand that a pending application in DSBS is not enough to establish certified status for award purposes.
Joint Venture
Ensure the WOSB or EDWOSB participant is certified in SAM and that the joint venture satisfies all requirements of 13 CFR 127.506 before claiming WOSB/EDWOSB eligibility.
Practical Implications
Contracting officers must verify certification in SAM, not just rely on a representation or a pending application in DSBS, before using WOSB/EDWOSB set-aside or sole-source authority.
A later SBA adverse decision can disrupt an already-awarded contract: agencies may need to terminate, stop options, and stop additional orders, so eligibility checks matter throughout performance, not only at award.
Procurement reporting must be corrected if SBA overturns eligibility, which can affect small business goal achievement and FPDS data quality.
Joint ventures are a common pitfall: the presence of a WOSB/EDWOSB participant is not enough unless that participant is certified in SAM and the JV meets the SBA joint venture rules.
Contractors should keep SAM and certification information current; stale or incomplete records can block award or create post-award risk if SBA later questions eligibility.
Official Regulatory Text
(a) Status as an EDWOSB concern or WOSB concern eligible under the WOSB Program is determined by the Small Business Administration in accordance with 13 CFR part 127 . (b) For a WOSB that seeks a WOSB or EDWOSB set-aside or sole-source contract, the contracting officer shall verify that the offeror— (1) Is registered in the System for Award Management (SAM); and (2) Is designated as a certified EDWOSB or WOSB concern in SAM (see 19.1505(d) for set aside procedures). Pending applications for certification are only in the Dynamic Small Business Search (DSBS) at https://web.sba.gov/pro-net/search/dsp_dsbs.cfm . (c) If there is a decision issued by SBA as a result of a current eligibility examination finding that the concern did not qualify as an EDWOSB concern or WOSB concern eligible under the WOSB Program, the contracting officer may terminate the contract, and shall not exercise any option, or award further task or delivery orders. Agencies shall not count or include the award toward the small business goals for an EDWOSB concern or WOSB concern eligible under the WOSB Program and must update FPDS from the date of award to reflect the final SBA decision. (d) A joint venture may be considered an EDWOSB concern or WOSB concern eligible under the WOSB Program if the EDWOSB or WOSB participant is certified in SAM (see section 19.1505(d) for set-aside procedures) and the joint venture meets the requirements of 13 CFR 127.506 .