Tensorust Performance Ledger · for small business specialists, PCRs, OIG analysts, SBLOs and contracts directors · built 2026-11-06

For the people who have to answer whether set-aside primes do the work.

If your job is limitations on subcontracting (an SBA procurement center representative, an OSDBU small business specialist, a contracting officer, an OIG analyst, a prime's small business liaison officer, or the contracts director at a small prime getting ready for an audit), you are asked a question the usual record cannot answer: only 4.6% of $1M+ set-aside labor and R&D awards report any subcontract in FSRS. The ledger adds a second record: each prime's set-aside labor dollars against the headcount it reports to the Labor Department on its own Form 5500, against peers buying the same work, with every innocent explanation the data can see checked first. Across all agencies that leaves 16 firms ($101M a year) to look at first. Start below, on your own, free: no account, nothing to send.

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Look up one firm

Any set-aside contractor with $250K or more in FY2025-27 to date (15,656 firms): its dollars by what was bought, its own 5500 headcount and filing ID, its peers and its flag status.

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The government cannot see who performs

The rule: on a services set-aside, the small prime must not pay more than half of what it is paid to firms that are not similarly situated (13 CFR 125.6, FAR 52.219-14). 51 firms bill $500K or more a year per Form 5500 participant on $674M a year of set-aside labor, against a peer median of $54K. Most of that has an innocent explanation the data can see. The 16 firms left to look at first include 9 on 8(a), SDVOSB, HUBZone, WOSB or other program set-asides, where only a subcontractor in the same program counts as the prime's own work.

Of 10,416 set-aside labor and R&D awards that drew $1M or more in FY2025-26 ($56.24B), only 480 (4.6%) report even one first-tier subcontract in FSRS. That is the only public record of who else did the work. SBA's Inspector General (Report 26-19, September 30, 2026) found the limit "not being interpreted, applied, monitored, or enforced consistently across the Government." The Form 5500 is the other half: an independent, sworn headcount filed with a different agency, by EIN, every year.

The capacity test

Set-aside labor and R&D services obligations per year (PSC B-X and A, excluding D?1x 'as a Service' subscriptions, V2xx travel and any award whose NAICS is construction or specialty trade), with each award's FY2025-26 obligations spread over the period they fund (Oct 1 2024 or the award's start, whichever is later, to its current end date; at least 2 years, at most 5), divided by the prime's active participants on its largest Form 5500 plan for its latest plan year. Peers are firms in the same PSC family with 5+ participants and $1M+ a year. Match: USAspending recipient name to 5500 sponsor name with the ontology's org_key, plus ZIP5 (mailing or location). Fallback: name + state when exactly one EIN carries that name in the state.

A firm is flagged when it holds $1M+/yr of set-aside labor/R&D work and bills $500K+ per active participant (8x the peer median, 2.2x the 90th percentile; it absorbs a 2x 5500 undercount).

The review queue, with the excuses already checked

A high dollars-per-worker number has innocent causes. The ledger checks each one it can see in the data and labels the flag, so a reviewer starts with the cases nothing explains.

We hand-checked 6 of the leading flags against public award descriptions. 2 were explained (pass-through parking fees remitted for the agency; software licensing carried under a services code) and moved to tier 3. 4 remain plausible leads ($52.6M a year): nothing public explains the gap yet, which is a reason to look, not a finding.

Subawards: 50 of 51 flagged firms report none in FSRS, but so do 1,760 of all 1,910 matched $1M+ firms, so a missing subaward is not by itself a signal. Annualizing each award over its period of performance (instead of a fiscal-year average) removed 10 of 61 flags that came only from obligations made up front.

Robustness: 6 tier 1-2 firms still bill $1M+ per participant ($32.0M a year), which survives a 2x undercount of the 5500. 16 of 16 tier 1-2 firms stay over $500K per participant under the stricter national match (the largest same-name sponsor anywhere in the US). These are triage signals, not findings of a violation. Work subcontracted to similarly situated firms counts as the prime's own (13 CFR 125.6(c)): on a plain small-business set-aside that is any small business, so an unreported small sub would be legal; on 8(a), SDVOSB, HUBZone and WOSB set-asides it must be a firm in the same program. Materials do not count against services limits; a 5500 counts plan-eligible employees only. Most matched $1M+ firms report no FSRS subawards at all, so a missing subaward is not by itself a signal.

By agency

The 8(a) cohort GSA is auditing

On October 21, 2026, SBA referred removed 8(a) firms to GSA for contract audits. The list has not been published. Across all 5,085 firms that held 8(a) set-aside work in FY2025-26 ($33.77B), 1,804 file their own Form 5500. 14 are flagged ($160M a year of labor/R&D); most carry a visible explanation, and the rest sit in the tier 1-2 review queue. Any firm list an auditor holds can be run against the ledger in one pass.

Software subscriptions bought as set-aside "services"

$6.42B of FY2025-26 set-aside obligations are PSC D?1x "as a Service" subscriptions, through 1,086 firms. That is resale of someone else's software, and much of it runs through the sanctioned reseller channel. Whether paying the publisher counts against the limit is the question OIG 26-19 says contracting officers answer inconsistently. The ledger reports it separately and never mixes it into the labor test.

Sources: USAspending Award Data Archive FY2025 + FY2026 (all contract transactions, as of 2026-10-06) and the USAspending bulk download API for FY2027 to date (pulled 2026-11-06); DOL EFAST2 Form 5500 and 5500-SF bulk datasets, filings received 2024-2025 (files as of 2026-11-02); FSRS first-tier contract subawards via USAspending, FY2025 to date; 13 CFR 121.201 from the eCFR API (2026-10-30); Tensorust Ontology (objects, links, obligations), read-only. FY2027 data covers 10,128 set-aside actions through the pull date. Public records, reorganized. A flag here is a lead for review, not a finding that any rule was broken: work done by similarly situated subcontractors counts as the prime's own (on a plain small-business set-aside, any small business), materials are excluded, and a 5500 counts plan-eligible employees only. Tensorust LLC is not affiliated with any agency or company named here.

Rankings: Set-aside work by PSC family and agency. Your own subcontractor list measured in 5 business days: 5-day sprint.