Everyone involved with government contracting knows, or should know, a little bit about registration in SAM.gov. Registration is now required for ALL federal contractors at the time they submit bids.
This blog post provides you with 5 things you should know about registering in SAM.gov.
1. Logging In.
In June 2018, SAM.gov changed its log in system. Now, SAM.gov users must have a login.gov user account. A login.gov account allows users to log into SAM.gov and a number of other government websites. Unlike the old SAM.gov login system, login.gov requires two-factor authentication. This means that you’ll first be required to put in your username and password. After this, login.gov will send a six digit security code to the phone number associated with your account. Even though you get a little more time than Tom Cruise, don’t wait too long to enter the code. Each code expires within five minutes. It should also go without saying, but, even with two-factor authentication don’t share your password, even with the SAM Help Desk or anyone from the SAM Program Office.
2. What you need before you register.
There are a number of pieces of information you should have on hand before you register, including the following:
• Your DUNS number. DUNS Numbers (parts of Dun & Bradstreet’s Data Universal Numbering System) are nine digit identification numbers associated with each physical location of your business. Acquiring a DUNS number is free online via this link. While the site indicates that you may acquire a DUNS number “within 1 business day,” its wise to allow for a few days to process.
• If you are a US tax paying entity, you need your Tax Id Number (TIN) and Taxpayer Name. Your TIN can be either an Employer ID Number (EIN) or Social Security Number (SSN) based on your business structure. You can apply for your federal TIN or EIN through the IRS here. Also note: your Taxpayer Name may be different from your legal business name! Make sure you verify the Taxpayer Name on your entity’s 1099, W-2, or W-4 forms.
• Your CAGE or NCAGE Number, if you already have one. You can check your CAGE/NCAGE number, or request a new one, here. If you don’t have one yet, no worries! You will be automatically assigned one after you register in SAM.gov.
• Your Electronic Funds Transfer (EFT) Information. You want to get paid! To do so, you need to provide your bank routing and account numbers.
3. Providing one or more NAICS codes.
We’ve discussed NAICS codes previously on this blog and on our YouTube Channel. When you are registering in SAM, you must supply at least one NAICS code associated with your business, but you can include as many as are applicable to you. You must mark only one as your Primary NAICS code however. Still, keep in mind that you can add, remove, or change NAICS codes whenever as your business grows or adapts.
4. TELL THE TRUTH!
While this one should be obvious, we cannot stress it enough! When filling out Core Data, you may be required to provide “proceedings data”; Specifically, you must disclose whether the business you are registering (or any of its principals) have been subject to a number of types of legal proceedings related to performance of a Federal contract in the last 5 years.
These proceedings include Federal or State (1) Criminal proceedings resulting in a conviction or other acknowledgement of fault; (2) Civil proceeding resulting in a finding of fault with a monetary fine, penalty, reimbursement, restitution, and/or damages greater than $5000, or other acknowledgement of fault; and/or (3) Administrative proceedings resulting in findings of faults with either a monetary fine or penalty greater than $5,000 or reimbursement, restitution, or damages greater than $100,000, or other acknowledgments of fault.
If you answer yes to any of these, you will be asked to provide additional, detailed information. This information will be made public through FAPIIS. In any case, however, it is best to disclose any relevant information! If you have any question about whether or not disclosure is required, its generally best to disclose. For specific questions on how to appropriately disclose information, you can also talk to a lawyer, like the ones here at Koprince Law.
In addition to the Core Data section, under the Representations and Certifications portion of your SAM.gov registration, the Government has created a “questionnaire” related to specific FAR and DFARS provisions contractors may have to comply with.
Questions 8 and 9 in particular, but other questions as well, require you to disclose whether “in the past three years, your entity, or any of its principals, has been convicted or had a civil judgment rendered against it for: commission of fraud or a criminal offense in connection with obtaining, attempting to obtain, or performing a public (federal, state, or local) contract or subcontract; violation of federal or state antitrust statutes relating to the submission of offers; or commission of embezzlement, theft, forgery, bribery, falsification or destruction of records, making false statements, tax evasion, violating federal criminal tax laws, or receiving stolen property.”
Your answers will be public here as well, but again, do not try to cover things up! Misrepresenting anything means your pants are likely to set on fire or, in any case, you are subject to facing serious consequences.
5. Finally, SAM.gov will be changing its format soon!
SAM.gov is scheduled to transition into what is currently beta.SAM.gov by late 2019. The new government website is intended to “merge ten ‘legacy’ award sites into one system,” to (hopefully!) make government contracting processes easier.
Currently, registration and updates should still be done via SAM.gov, but the government welcomes use of beta.SAM.gov and feedback on the system. When changes do roll around, however, the government has clarified that if you have a current SAM.gov registration “you will not need to re-register your entity, but you will need to create a new beta.SAM.gov user account. Your entity data will migrate to the new site. You will be able to claim your legacy SAM.gov roles using your new beta.SAM.gov account.” Keep your eyes peeled for updates on the modified system!
If you want additional information on registering for SAM.gov, the government has put together a pretty thorough handbook, available online along with a number of descriptive videos, or you can contact the Federal Service Desk for additional assistance.
Questions about this post? Or need help with a government contracting legal issue? Email us or give us a call at 785-200-8919.