According to SBA contracting officials, the government’s real question is simple: does the certified small business actually staff, supervise, and control the work it won? For many federal set-asides, the answer must be supported by labor records, invoices, org charts, and a clear workshare model that matches the solicitation. FAR 52.219-14 is not a paper exercise; it is a performance test. Agencies such as GSA, DHS, VA, NASA, and DoD are increasingly asking for evidence that the prime is not merely a pass-through entity. That means the prime must be able to show who wrote the deliverables, who managed the schedule, who billed the hours, and who carried the performance risk. If the subcontractor is doing the heavy lifting while the prime only signs the invoice, SBA and the contracting officer may treat the arrangement as noncompliant. In 2026, that scrutiny is especially strong on service, IT, and professional services contracts where labor mix is easy to verify after award.