It’s official: If you intend to pursue a federal contract, your business must be registered in the System for Award Management (SAM) before you submit a bid, proposal, or quotation. The new rule that makes this clear goes into effect on October 26, 2018.
Any wiggle room that may have existed in the past has been eliminated. SAM registration is now imperative if you are interested in federal contracting.
It used to be that SAM registration was required before a contract could be awarded. The Federal Acquisition Regulation (FAR) at Subpart 4.1102(a) made that clear. But that requirement was always a bit ambiguous since another provision of the FAR (Subpart 52.204-8(d)) said that bidders and proponents had to complete the representations and certifications in SAM as a condition of making their offer. As a matter of practical interpretation, most federal contracting officers simply made sure that an offeror’s SAM registration was complete before awarding the offeror a contract.
That latitude goes away on October 26, 2018. On that date, FAR Subpart 4.1102 is officially amended to require all entities (i.e., vendors, including joint ventures) to be registered in SAM at the time they submit an offer (a bid or proposal) or submit a quotation to a federal agency. In essence, vendors who are not registered in SAM are ineligible to submit offers or quotes – effective October 26, 2018.
Keep in mind that the SAM registration process can take time to complete. If you’re planning to compete for a federal contract in the future, you should complete your SAM registration as far in advance as possible. And, if you are already registered in SAM, remember that your SAM registration must be renewed at least annually – and renewed whenever any part of your registration needs to be updated.
If you need help with your company’s SAM registration, feel free to request counseling with the Virginia Procurement Technical Assistance Program (Virginia PTAC). If you are an existing client and aren’t sure which counselor to reach out to, contact your local office for scheduling: https://virginiaptac.org/contact/.
If you are located outside of the state of Virginia, you can find the procurement technical assistance center (PTAC) nearest you at: http://www.aptac-us.org/contracting-assistance
Remember: There is never a fee to register in SAM as a government contractor. PTACs are available with no-cost help to get you through the process.
SAM is located at: https://sam.gov. But before beginning the SAM registration process, you must first take care of the following:
- Obtain a DUNS Number by registering your Legal Business Name and Physical Address with Dun & Bradstreet (D&B). If you don’t already have a DUNS Number, you can request a DUNS Number for FREE from D&B at: http://fedgov.dnb.com/webform
- Make sure you have a Taxpayer Identification Number (TIN) associated with the Legal Business Name registered with D&B. To obtain information from the IRS on how to obtain a TIN, visit: https://www.irs.gov/individuals/international-taxpayers/taxpayer-identification-numbers-tin
- Have your bank’s routing number handy, including your bank account number and your bank account type (i.e., checking or savings). You’ll need this information to set up Electronic Funds Transfer (EFT) in SAM. The federal government makes virtually all contract payments via EFT.
- The first time you log in to SAM.gov, you’ll be asked to create a login.gov user account (if you don’t already have one). Going forward, you will use your login.gov username and password every time you log in to SAM.gov. Existing SAM.gov usernames and passwords no longer work.
Article adapted courtesy of the Georgia Tech Procurement Assistance Center