Tag Archives: System for Award Management

Dialing Down: SAM Registration Not Constantly Required

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As we’ve written about on the blog, protests have been decided because the offeror was not registered in SAM for the entirety of the proposal review process period. For instance, in this post, we discussed a GAO decision where GAO held that the FAR requires offerors to maintain SAM registration throughout the evaluation period, meaning from proposal submission to award of the contract. A COFC case came to the same conclusion. Well, the federal government didn’t like the result and has published an interim rule to remedy it.

In a recent interim rule effective November 12, 2024, the FAR is being updated to clarify that “the offeror must be registered at time of offer submission and at time of contract award, but would not be required to be registered at every moment in between those two points.”

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Back to Basics: Registering in SAM.gov

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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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SBA Takes Action Following OIG Investigation of Suspension and Debarment Process

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On September 18, 2019, SBA’s Office of Inspector General released an Audit Report summarizing a recent audit of SBA’s Suspension and Debarment Process. The purpose of the audit was to determine whether SBA “had sufficient controls in place to prevent suspended or debarred entities from receiving federal contracts through SBA’s preference contracting programs and small business loans.”

Through its investigation, OIG discovered SBA lent and awarded millions of dollars to businesses otherwise ineligible to receive these funds under SBA’s suspension and debarment guidelines. While SBA disagreed with some of OIG’s findings, SBA did agree to take some steps to address OIG’s findings and recommendations.

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Hack Response: Notarized Letters Now Required for SAM.gov

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Because of a recent cyber attack on the System for Award Management, the Federal Service Desk is requiring new contractors to submit a signed notarized letter in order to be registered. Later this month, existing registrants seeking to update or renew profiles will have to do the same.

This move comes after the General Services Administration acknowledged on March 22 that the inspector general is looking into a hack of the SAM.gov database, in which the hackers changed the banking information for “a limited number” of contractors.

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

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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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