Overview
This section establishes the mandatory requirement for contractors to be registered in the System for Award Management (SAM) prior to submitting an offer or quotation. It outlines specific exceptions to this rule, primarily for emergency, classified, or overseas operations, and dictates how Contracting Officers must use and maintain SAM data throughout the contract lifecycle.
Key Rules
- Registration Timing: Offerors and quoters must generally be registered in SAM at the time an offer or quotation is submitted to satisfy annual representations and certifications requirements.
- Primary Exceptions: Registration is not required for:
- Micro-purchases using a Governmentwide commercial purchase card for both purchase and payment.
- Classified contracts where SAM data could compromise national security.
- Military, humanitarian, or emergency operations (e.g., Stafford Act responses).
- Contracts awarded under "unusual and compelling urgency."
- Foreign vendors for work performed outside the U.S. for actions at or below $40,000.
- Data Integrity: Contracting Officers must use the legal business name and address exactly as provided in SAM; they are expressly prohibited from making changes to the data retrieved from SAM when drafting contract documents.
- Name Changes and Novations: Contractors must provide at least one business day's notice to the Contracting Officer before changing their name in SAM and must comply with FAR Subpart 42.12 procedures.
- Payment Consequences: Failure to comply with name-change notification requirements or providing incorrect SAM information allows the government to invoke the "Suspension of Payment" paragraph of the Electronic Funds Transfer (EFT) clause.
- Assignees: Assignees for the purpose of assignment of claims must be registered in SAM separately from the prime contractor.
Practical Implications
- Eligibility Threshold: For most commercial and federal procurements, a vendor's failure to have an active SAM registration at the moment they hit "submit" on a proposal renders them ineligible for award.
- Administrative Rigidity: Because Contracting Officers cannot manually edit contractor data in their systems, contractors must ensure their SAM profile is 100% accurate; any errors in the legal name or address must be fixed by the contractor in SAM before the contract can be correctly issued.
- Corporate Changes: Companies undergoing mergers, acquisitions, or simple name changes must coordinate closely with their Contracting Officer to avoid immediate suspension of payments.