FAR Council and GSA Fix Timing of Required SAM Registration
The System for Award Management (SAM) is the exclusive, government-wide, registration system for all companies seeking to do business with the Federal Government. All offerors must be registered in SAM before being awarded a federal contract. SAM is also available to grantees and others, including foreign companies. Companies are well advised to begin a new registration, or complete their annual updates, well in advance of deadlines to avoid potential system issues or preclusion from being awarded work. Since 2018, t he FAR [i] has requires that a vendor be registered at the time of submission of an offer “and shall continue to be registered until time of award, during performance, and through final payment of any contract,” unless an exception applies. Recent Court of Federal Claims and Government Accounting Office (GAO) decisions have strictly interpreted the FAR provision regarding continuous registration in SAM, which has resulted in several companies being disq...