Government
Counting Employees for HUBZone Purposes: The Clear Line of Fractured Standard
Certification in SBA’s1 HUBZone Program requires firms, among other things, to meet two employee- based conditions. So, to ensure compliance, a firm must first grasp how SBA counts “employees.” In addition, an applicant firm must also realize that, in some cases, SBA will count the employees of its affiliates (for size purposes under SBA’s regulations)2 as if they were the applicant firm’s own employees. Indeed, SBA, using the totality of the circumstances, will aggregate a firm’s employees with its affiliate’s employees unless a clear line of fracture separates the two.