On February 19, the Office of Hearings and Appeals (OHA) denied an appeal from an unsuccessful bidder who argued the awardee was large due to an acquisition that occurred while the award was pending. OHA found that Small Business Administration (SBA) regulations prohibit awards to concerns where a merger or acquisition occurs, resulting in the new business becoming “large,” within 180 days of the initial offer rather than a final proposal revision. This understanding follows the general rule that SBA determines a concern’s size as of the date of the initial offer. We explore the decision and its implications below.