Contrary to a common misconception, a contractor need not list the solicitation’s NAICS code in its SAM profile in order to qualify for contract award.
In a recent bid protest decision, the GAO confirmed that the government may award a contract to a small business even if the awardee does not list the solicitation’s NAICS code in its SAM profile.
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.