All Small Mentor-Protege Program

The All Small Mentor-Protege Program is an SBA program established by the National Defense Authorization Act of 2013 that extends mentor-protege benefits to any SBA-certified small business, not just 8(a) participants, allowing proteges to form joint ventures with mentor firms and compete for set-aside contracts without the affiliation between mentor and protege counting against size eligibility.

What is the All Small Mentor-Protege Program?

Prior to 2016, formal SBA mentor-protege arrangements with the affiliation waiver were available only to 8(a) Business Development Program participants. The All Small program opened the same structure to HUBZone-certified, SDVOSB-certified, VOSB-certified, and WOSB/EDWOSB-certified small businesses, as well as to small businesses that hold only general small business status without a specialized certification.

The mechanics mirror the 8(a) program: a mentor (which may be a large or small business in good standing with the federal government) and protege execute a written mentor-protege agreement (MPA) committing the mentor to provide defined developmental assistance. The SBA reviews and approves the MPA. Once approved, the mentor and protege may form a joint venture that qualifies as small for set-aside competitions based solely on the protege's size, waiving the standard affiliation analysis that would otherwise combine the two firms' sizes.

Proteges may have two SBA-approved mentor-protege agreements simultaneously, one under the All Small program and one potentially under the 8(a) program if the protege also holds 8(a) certification. Mentors may have an unlimited number of protege relationships but must demonstrate they can provide genuine assistance to each. The SBA monitors active relationships through annual reports and may terminate agreements that lack real developmental activity.

Why the All Small Mentor-Protege Program Matters for Government Contractors

For non-8(a) small businesses, the All Small program provides the same competitive leverage that 8(a) firms have used for decades: the ability to team with a large, resource-rich partner for set-aside competitions without losing small business status. For large businesses, it is the primary legal mechanism to participate in SDVOSB, HUBZone, or WOSB set-aside competitions through a joint venture without needing to hold the underlying certification themselves.

Example

A WOSB-certified cloud services firm with limited past performance on large contracts executes an SBA-approved All Small mentor-protege agreement with a large DoD IT contractor. They form a joint venture registered in SAM.gov and submit a combined proposal for a $9M WOSB set-aside at the Air Force. The large contractor's past performance and technical depth strengthen the proposal; the WOSB's certification preserves set-aside eligibility. The joint venture wins.

Frequently Asked Questions

How is the All Small program different from the 8(a) mentor-protege program?

The 8(a) program is limited to firms actively enrolled in the 8(a) Business Development Program. The All Small program is open to any SBA-certified small business regardless of 8(a) status. Both provide the same affiliation waiver for approved joint ventures. An 8(a) firm may choose either program; other small businesses must use the All Small program.

Can the mentor be a small business?

Yes. Mentors in the All Small program may be large or small businesses, but they must demonstrate the technical, managerial, financial, or contracting experience to provide meaningful developmental assistance to the protege. A successful mid-sized contractor that has graduated from small business status can serve as a mentor to a smaller firm still qualifying as small.

What happens to joint venture eligibility if the protege loses its certification?

If the protege loses its SBA certification (for example, an SDVOSB firm's ownership changes), the joint venture may no longer qualify for set-asides under that certification category. The SBA-approved mentor-protege agreement also depends on the protege remaining eligible for the program. Firms should monitor their certification status and notify the SBA of any material changes affecting eligibility.

Is developmental assistance under the All Small program tax-deductible for the mentor?

Mentor firms may be able to treat certain developmental assistance provided to the protege as allowable costs on cost-reimbursement federal contracts, consistent with FAR Part 31 cost principles. The specific treatment depends on the nature of the assistance and the mentor's indirect rate structure. Firms should confirm with their accounting system and DCAA-compliant cost accountants before treating such costs as contract charges.