What NAICS 236220 covers
NAICS 236220 is the federal government's primary code for commercial and institutional building construction. It covers new construction, additions, alterations, and renovations of buildings that are not single-family or multifamily residential. Federal work under this code runs the full range: military barracks, VA medical centers, federal courthouses, border patrol stations, research laboratories, and administrative office buildings.
The code does not cover civil engineering work (bridges, roads) or specialty trade contractors (electrical, plumbing). Those fall under different NAICS codes. If your company self-performs general contracting on building projects, 236220 is your primary code. Subcontractors who bundle GC services may also register it as a secondary code to appear in agency searches.
What federal agencies spend under this code
The federal government awards over $8 billion per year under NAICS 236220. That number has held roughly flat since FY2021 but construction inflation has compressed margins, so effective award volume in constant dollars is declining slightly.
The two dominant buyers are the U.S. Army Corps of Engineers (USACE) and the Naval Facilities Engineering Systems Command (NAVFAC). Together they account for approximately 55 to 65 percent of total annual dollars. Other significant buyers include:
- The General Services Administration (GSA), primarily for courthouses, federal office buildings, and land ports of entry
- The Department of Veterans Affairs (VA), which runs a sustained capital program for medical center upgrades and new outpatient clinics
- The Air Force Civil Engineer Center (AFCEC), primarily through USACE as the contracting agent
- U.S. Customs and Border Protection (CBP) for ports of entry and sector headquarters
USACE publishes its project pipeline through its Procurement Forecast tool at usace.army.mil. The VA publishes a rolling forecast through its Office of Construction and Facilities Management at cfm.va.gov. Both are worth checking quarterly.
Set-asides most common under this code
Federal construction contracting under 236220 uses the full range of small business set-asides. The distribution varies by agency and project size.
8(a) Business Development Program is the most consistently used set-aside for projects under $7.5 million. The SBA-to-agency direct award mechanism makes the contracting process faster for agencies, which is why they reach for it on smaller renovations and repairs. If you hold an 8(a) certificate, projects in the $1 million to $7 million range are realistic entry points. Above $7.5 million, the agency must compete the work among 8(a) firms rather than sole-source.
HUBZone is heavily used by USACE and the VA on mid-tier projects. Both agencies face internal goals for HUBZone utilization, and construction contracts are an easy way to move the needle on those numbers because the projects are geographically fixed. If your principal office is in a HUBZone and your workforce meets the 35 percent residency threshold, this certification can open solicitations that small business competitors without HUBZone status cannot access.
SDVOSB (Service-Disabled Veteran-Owned Small Business) is particularly relevant for VA work. Under the Veterans First Contracting Program, the VA is required to set aside contracts for SDVOSBs or VOSBs before considering other small business programs. VA construction budgets run over $1 billion annually, and the program is active at both the medical center and national levels.
WOSB (Women-Owned Small Business) set-asides apply in industry groups where the SBA has determined women-owned firms are underrepresented. NAICS 236220 qualifies. Contracts under $4 million (or $6.5 million for manufacturing) may be set aside exclusively for WOSBs or economically disadvantaged WOSBs (EDWOSB).
Contract vehicles that list this NAICS
Winning individual open-market solicitations is one path. Getting onto an IDIQ or GWAC is often faster for sustained work.
USACE Multiple Award Task Order Contracts (MATOCs) are the backbone of Army construction. These are regionally scoped IDIQs with a pool of pre-qualified small businesses. Each USACE district typically runs its own small business MATOC for construction and renovation. Solicitations are posted to SAM.gov and competition is limited to the pool. Getting on a district MATOC is effectively a key to the building.
NAVFAC Multiple Award Construction Contracts (MACCs) function the same way for Navy, Marine Corps, and other naval installations. NAVFAC Southwest, Southeast, Mid-Atlantic, and Northwest each have active MACCs. Awards under these contracts range from $100,000 to over $10 million per task order.
VA Technical and Construction Excellence Program (T-CXCELLENCE) is the VA's small business IDIQ for construction. It is competed on a small business set-aside and covers the full range of building construction at VA medical centers and clinics.
GSA Multiple Award Schedule (MAS) SIN 531 series covers facilities maintenance and repair rather than new construction, but renovation and alteration work that does not exceed certain dollar thresholds can be placed against those SINs. It is worth holding but is not the primary vehicle for major new construction.
SBA size standard
For NAICS 236220, the SBA size standard is $45 million in average annual receipts, measured over the firm's three most recent fiscal years. This is the threshold for qualifying as a small business for federal contracting purposes.
Note that the size standard applies at time of offer, not at time of award. If you grow beyond $45 million between proposal submission and contract award, you may still qualify if you met the standard when you submitted your offer. Firms should verify current revenue against the standard annually and before bidding any new contract.
Emerging small businesses and very small firms should also review whether they qualify under the SBA's 8(a), HUBZone, or WOSB programs before relying solely on the broad small business designation.
Certifications that give a competitive edge
In order of practical impact for most firms new to federal construction:
- 8(a) certification gives access to sole-source awards up to $7.5 million and set-aside competitions. The program runs nine years. For a construction firm with no federal past performance, this is the most direct route to a first contract.
- HUBZone certification activates a statutory 10 percent price evaluation preference on full-and-open competitions and makes the firm eligible for HUBZone-only set-asides. USACE and NAVFAC use both mechanisms actively.
- SDVOSB or VOSB is essential for VA work. CVE (Center for Verification and Evaluation) verifies these certifications. Without it, you cannot compete on VA-set-aside solicitations.
- DBE (Disadvantaged Business Enterprise) certification is required for participation as a prime or sub on federally funded transportation and infrastructure projects. For building construction specifically funded by federal highway, transit, or airport grants, the prime contractor must meet DBE subcontracting goals. If you hold DBE certification, you become a sought-after subcontractor on those projects. DBE is administered at the state DOT level and certifications are reciprocal across state DOTs through the UCP.
Finding active solicitations
SAM.gov (beta.SAM.gov is now the primary interface) is the mandatory posting location for all federal solicitations above the micro-purchase threshold. Filter by NAICS code 236220, set-aside type (small business, 8(a), HUBZone, SDVOSB/VOSB), and agency to narrow results. Save the search as a daily alert.
Agency forecast tools surface opportunities before they reach SAM.gov. Key ones:
- USACE Procurement Forecast: search by district and project type
- VA Office of Construction and Facilities Management forecast: published quarterly at cfm.va.gov/construction/projectForecasting/
- GSA Forecasting Tool: forecast.gsa.gov
FPDS-NG (the Federal Procurement Data System) is useful for market research. Search for 236220 awards over the past three years by agency and geography. Identify which contracting officers are actively awarding construction in your region, what dollar ranges they use, and which set-asides they favor. This takes two hours and will shape your entire capture strategy.
Industry days and pre-solicitation conferences are worth attending for large MATOC competitions. USACE and NAVFAC host these to brief potential offerors on scope and requirements before releasing the solicitation. Attendance is logged and signals genuine interest to the contracting office.
A realistic path for a new entrant
A construction firm with no federal past performance should expect a 12 to 24 month runway before winning a first prime contract. Here is what that path looks like in practice.
Year one, months 1 to 6: Get registered. SAM.gov registration is mandatory for all federal contractors. Obtain a UEI (Unique Entity Identifier), complete your SAM entity registration, and ensure your NAICS codes are correct. Apply for any certifications you qualify for. 8(a) applications currently take 60 to 90 days for complete applications.
Year one, months 6 to 12: Pursue subcontracting. Find prime contractors who hold MATOC positions with USACE or NAVFAC in your region. Offer to sub on current task orders. Federal primes need to meet small business subcontracting plan requirements, and a certified 8(a) or HUBZone sub is valuable to them. One or two subcontracts generates the past performance you need.
Year two: Bid on prime contracts using your subcontract past performance as evidence of capability. Target projects in the $500,000 to $2 million range on set-aside solicitations. Write a tight technical approach. Price competitively but not recklessly; the government evaluates "price realism" and an unrealistically low bid can disqualify you.
Your first federal award in construction will likely be a renovation or repair project, not a new hospital wing. That is normal. Task orders on a MATOC position built over two years are worth more than a single large contract in terms of long-term revenue stability. Build the relationship with the contracting office. Perform well. The next task order is easier to win than the first.
The path is slow by commercial standards. But the federal government awarded 236220 contracts to over 3,000 distinct small businesses in FY2023. Most of them started exactly where you are.
