SAM Registration: What The Heck Is An “Immediate Owner?”

Government contractors who have attempted to recently register or re-register in the SAM database have been confronted with new questions asking about an “immediate owner” and a “higher-level owner.”  These new SAM questions have caused some confusion about what information, if any, a contractor must provide in SAM with respect to an “immediate owner” or “higher-level owner.”

The new questions originate in a recent amendment to the FAR, which requires all SAM registrants, if owned by another entity, to identify that entity by legal name, CAGE code, and type of ownership.  This blog post breaks down the new rule and explains when this rule will come into play.

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GSA Contractor Team Arrangement: Single-SIN Restriction Was Appropriate

A procuring agency reasonably required all members of a SDVOSB set-aside GSA Contractor Team Arrangement to possess a certain Federal Supply Schedule contract and Special Item Number.

In a recent bid protest decision, the GAO held that restricting CTAs to holders of a certain Schedule and SIN was appropriate because all of the supplies to be procured fell within the identified Schedule and SIN.

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GAO: Agency Need Not Consider Omitted Past Performance Information

An agency has no obligation to consider outside information bearing on an offeror’s past performance when the offeror fails to include information in its proposal.

In a recent bid protest decision, the GAO concluded that an agency had no obligation in its past performance evaluation or cost evaluation to import and consider favorable information the offeror could have, but did not include in its proposal.

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SDVOSB Fraud: Guilty Plea In “Rent-A-Vet” Case

A Nebraska man has pleaded guilty to fraud and money laundering charges stemming from a SDVOSB “rent-a-vet” scheme under which an ineligible business received 45 SDVOSB contracts.

According to a Department of Justice press release, the man faces up to 24 months in prison and financial penalties.  He and his companies also have been suspended from government contracting and face the likelihood of debarment.

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