Prime vs. Subcontracting: When to lead, when to team

Two developments just shifted the prime-vs-sub calculus for small federal contractors. First, the Pentagon finalized the CMMC rule; requirements start appearing in solicitations beginning 11/10/2025 with a phased rollout over three years. Translation: cybersecurity readiness is no longer a “someday” item, your role choice will hinge on your CUI/FCI exposure and your readiness to pass assessments. Second, access to huge swaths of services and IT work continues to flow through mega-vehicles—OASIS+ (still navigating protests), SEWP V (extended through 10/31/2025 while SEWP VI moves forward), and CIO-SP4 (still in flux). If you’re not on a vehicle, you’ll often need to team with someone who is.

What happened (plain-language summary)
• CMMC is real, and it’s near. DoD can include CMMC clauses starting 11/10/2025, with a phased implementation. Level 2 will often require third-party assessments; primes will push flow-down and verification onto subs.
• Big vehicles gatekeep work. GSA’s OASIS+ selections are still drawing protests, and GAO task-order protest thresholds are generally >$10M for civilian-agency orders and >$35M for DoD/NASA/USCG orders (FY25 NDAA); some DoD orders placed under civilian GWACs may still be treated under the $10M civilian threshold. SEWP V is extended to avoid a gap while SEWP VI processes; CIO-SP4 remains slowed by corrective actions.
• Small-business demand remains strong. SBA released the FY2024 Small Business Procurement Scorecard in July 2025, agencies are still under pressure to hit (and beat) small-business goals, but vehicles and compliance are deciding who gets to play. 

Why it matters to small businesses
If you can’t clear the CMMC bar by the time it shows up in your lane, subcontracting under a compliant prime may be your fastest path to revenue, CPARS, and technical experience—without carrying the full audit load on day one. Conversely, if your work is mostly civilian/non-CUI or your controls are mature, priming the right size of opportunity (especially set-asides) can deliver margin, control, and direct past performance. Meanwhile, if you’re shut out of OASIS+, SEWP VI, or CIO-SP4, teaming becomes a market-entry strategy, not a consolation prize.

A fast decision framework (lead vs. team)
Ask these in order and be brutally honest with the answers:

1. Data sensitivity & cyber posture:
   • Handling CUI/FCI in DoD pipelines within 6–12 months? If your CMMC Level 2 posture isn’t audit-ready, subcontract near-term under a compliant prime while you close gaps; pursue prime work where only self-assessment applies (e.g., CMMC Level 1 or civilian work). 

2. Vehicle access:
   • On OASIS+, SEWP V/VI, CIO-SP4, or a relevant BPA/IDIQ? If no, team with primes already on vehicle and target task orders to build references; track SEWP VI onboarding while SEWP V remains available through 10/31/2025.
   • For OASIS+ (a GSA civilian MAC), GAO generally lacks jurisdiction for task-order protests under $10M; for DoD/NASA/USCG orders, the threshold is $35M—though DoD orders placed under civilian GWACs have been treated under the $10M civilian threshold in GAO decisions. 

3. Certifications leverage:
   • If you hold sba 8a certification, women owned small business certification (WOSB/EDWOSB), or disabled veteran small business certification (SDVOSB), you can prime set-asides sized to your capacity—or bring those to a team and negotiate better scope/fees as a must-have partner. Strengthen your pipeline with 8a certification assistance, sba 8a certification services, and 8a contracts services if 8(a) eligibility is on the table.

4. Past performance reality check:
   • Thin CPARS? Start as a sub to harvest CPARS-eligible roles and references, then step up to prime small, winnable set-asides. Build in Government Contract Proposal Writing support so your narrative actually sells the leap.

5. Market fit by code:
   • Validate your contractor NAICS code. Use the right naics code for government contractors on each pursuit (and consider the best NAICS codes for small business niches where competition is thinner). A misaligned code can sink eligibility and size status before you bid.

6. Non-contract entry ramps (for tech/R&D firms and nonprofits):
   • Use SBIR Grant Assistance to enter defense/agency labs and convert wins into follow-on contracts. If you’re a 501(c)(3), Grant Writing for Nonprofits can seed relationships that later translate into services buys.

Actionable next steps (90-day plan)
• Map your lanes: Split pipeline by CUI/FCI exposure. Tag each opportunity with expected CMMC level and choose prime vs. sub accordingly.
• Pick three vehicles to penetrate: Identify one you’re on (prime), one you’ll enter via contractor teaming arrangement (sub), and one you’ll target for the next on-ramp (JV/mentor-protégé). Track SEWP VI milestones and OASIS+ task-order rhythms.
• Tune your small-biz edge: Refresh your federal contracting certifications story (8(a), WOSB, SDVOSB), align your government contracting certification process, and update boilerplate for teaming/JV agreements.
• Sharpen capture artifacts: Build 2–3 proposal shells aligned to your top NAICS, including pricing guardrails and partner workshare rules.
• Negotiate like a prime, even as a sub: Push for meaningful workshare, key labor categories, and consent-to-name in the prime’s past performance. Protect your IR&D and pipeline.

Big picture
For most new or scaling firms, a hybrid strategy wins: subcontract to de-risk cyber and vehicle access on complex orders while you prime targeted set-asides where you’re clearly the best value. Agencies still need small businesses; the gatekeepers are evolving. Choose your role deliberately, then execute.

Related read on our site: Which Federal Contracting Role is Right for Your Small Business? If today’s framework helped, this post goes deeper on pros/cons, pricing control, and past performance tradeoffs. 

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