Overview
FAR Subpart 4.11 establishes the policy and procedures requiring contractors to be registered in the System for Award Management (SAM) prior to the submission of offers or quotations. This centralized database serves to increase the visibility of vendor sources and provide the federal government with a single, common source of validated vendor data and representations.
Key Rules
- Timing of Registration: Generally, offerors and quoters must be registered in SAM at the time they submit an offer or quotation to the government.
- Mandatory Data Accuracy: Contracting Officers (COs) must use the exact legal business name and address found in SAM. They are prohibited from making manual changes to the data retrieved from the system.
- Exemptions: Registration is not required for:
- Micro-purchases using the Governmentwide commercial purchase card for both purchase and payment.
- Classified contracts where SAM registration might compromise national security.
- Specific deployed military, foreign diplomatic, or emergency operations.
- Contract actions at or below $40,000 awarded to foreign vendors for work performed outside the U.S. (if registration is impractical).
- Contracts awarded under "unusual and compelling urgency."
- Urgent and Compelling Exception: If a contract is awarded due to extreme urgency, the contractor has 30 days after award (or until 3 days before the first invoice) to complete registration.
- Disaster Response: For debris removal or emergency relief within the U.S., COs are required to consult the Disaster Response Registry within SAM.
Responsibilities
- Contracting Officers (COs):
- Verify SAM registration using the Unique Entity Identifier (UEI) at the time of offer submission.
- Ensure the UEI and Electronic Funds Transfer (EFT) indicators are included in documents sent to payment offices.
- Consult the Disaster Response Registry for relevant emergency solicitations.
- Protect against improper disclosure of sensitive information contained in SAM.
- Contractors/Offerors:
- Maintain active registration to comply with annual representations and certifications.
- Provide written notification to the CO at least one business day before changing a name or transferring assets in SAM.
- Ensure that any "Assignees" (for assignment of claims) are separately registered in SAM.
- Payment Offices:
- Authorized to suspend payments if SAM information is inconsistent with the contract or if unauthorized name changes occur.
Practical Implications
- Bid Responsiveness: Failure to be registered in SAM at the exact time of offer submission can result in an offer being rejected as ineligible, unless a specific exemption applies. This is a common pitfall for new contractors.
- Payment Bottlenecks: Because the FAR mandates a "matching" principle between SAM and the contract schedule, any discrepancy in the legal name or address can trigger a "Suspension of Payment" under EFT clauses. Contractors must synchronize their SAM updates with formal contract novations or name-change agreements to avoid cash flow interruptions.
- Emergency Sourcing: During natural disasters, the government uses the Disaster Response Registry to find local vendors. Firms seeking disaster relief work must ensure they are not only in SAM but specifically registered in the Disaster Response sub-section to be visible to agencies.
- Administrative Compliance: The inclusion of clauses 52.204-7 and 52.204-13 makes SAM registration a continuing obligation throughout the life of the contract, not just a one-time entry requirement.