GAO Reminder: Joint Ventures Must Register on SAM

SAM.gov is like the home base of federal government contracting. Everything in federal government contracting seems to either start there, or require using SAM in some fashion. As a consequence, contractors are expected to register on SAM to work in federal contracting. However, it can be easy to overlook registering a joint venture entity on SAM, when contractors making up the joint venture are already registered on SAM. GAO recently took the opportunity to remind contractors of the need to register their joint venture separately on SAM through a bid protest decision.

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GAO: Don’t Slip Up on SAM Registration, Even for One Day

If federal contracting had a proverbial town square, it would be SAM.gov. So much federal contracting activity flows through or starts there. A large portion of SAM is contractor information. Contractors are required to be on SAM and are expected to keep their profiles on SAM updated. A “hot off the presses” GAO ruling has confirmed that the timing of SAM registration can make or break a contractor’s winning bid.

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COFC: Lapsed SAM Registration During Proposal Evaluations Makes Offeror Ineligible for Award

It’s a tale as old as time, and I’m not talking about “Beauty and the Beast.” I’m talking about an offeror who failed to comply with the registration requirements in FAR 52.204-7. What’s FAR 52.204-7? It’s the FAR provision that requires, among other things, all offerors to be registered in the System for Award Management, or SAM as it is better known. And, as we have seen many times before, there is no way around this rule. Often, failure to be registered in SAM limits an offeror’s eligibility before award is made, making the offeror ineligible for award. However, this time, it affected the award that had already been made, resulting in the court entering a preliminary injunction against the government continuing with its original award.

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Back to Basics: Registering in SAM.gov

SAM.gov, short for System for Award Management, is the entry point for federal contractors to interface with the government. So, it is a basic starting point for every federal contractor. But your SAM.gov profile also needs to stay up to date and be up to date at time of bid submission, and failure to keep your SAM profile active can cause problems, even for established contractors. Everyone involved with government contracting knows, or should know, a little bit about registration in SAM.gov.

This post walks you through the most important things you should know about registering in SAM.gov.

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A Slight Deviation: DoD Implements Temporary Verification Requirement while SAM Updates

On a daily basis, the Department of Defense (DoD) issues innumerable memorandums and orders, as one might expect when dealing with one of the largest institutions in human history. Most of these have little to no impact for most government contractors. However, a recent class deviation is an exception, as it should make things easier for the many contractors that use small business joint ventures in contracting with the DoD.

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2022 NDAA Requires Prompt SAM Update If SBA Issues Adverse Size Determination

If, as the result of a size protest or appeal, the SBA makes a final determination that a company is not a small business, the company will be required to update SAM within two days to reflect that it is no longer small. And if the company doesn’t recertify within two days, the SBA will do the honors and update the company’s SAM profile.

This tough new requirement is part of the compromise version 2022 National Defense Authorization Act, which is likely to be signed into law in the coming weeks, although it is unclear when the SBA’s regulations will be revised to implement the change.

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