The U.S. Government Accountability Office (GAO) recently released a decision that denied a contract award based on inactive SAM registration for the assumed awardee. This has sent a shockwave of concern across the industry, as many overlook this portion of the process.

As a new federal contractor, one of the first items you likely tackled was registering with the System for Award Management (SAM). Information provided to this database includes: 

• • Company legal business name
  • Trade style, doing business, or other name by which your entity is commonly recognized
  • Company physical street address, city, state, and zip code
  • Company mailing address, city, state and zip code (if separate from physical)
  • Company telephone number
  • Date the company was started
  • Number of employees at your location
  • Chief executive officer/key manager
  • Line of business (industry)
  • Company headquarters name and address (reporting relationship within your entity)

Once this information is processed, you are active in the system for 365 days. Then, you have to re-enroll. This may sound trivial to those who have been in the game a while, but with this recent decision, it’s important to ask yourself who will manage your status post-initial registration. Now is a good time to make that decision so you don’t meet the same fate as the contractor in this scenario

According to Federal Acquisition Regulation (FAR) provision 52.204-7, contractors must be SAM registered and establish an active status from the time they submit a proposal, through contract award, including the final payment for the award.

Keeping your SAM status may seem simple, but when you are hustling to bid and win a contract, a year can go by in a flash. So, who is keeping track of it for your business? Rather than assume somebody else is keeping track of your SAM registration, you should make it someone’s responsibility now.

The awardee who was denied the contract protested the decision by the GAO, but in the end, the ruling stands. The compliance for registration is detailed in the aforementioned FAR provision as the contractor’s responsibility. So what may seem a trivial detail, as the expired active status still maintained accurate information, has evolved into a hefty price to pay for a minor oversight.

Lesson learned: make sure someone has an alert in their calendar to update your business’s status before it expires. If you haven’t, you can be sidelined for awards that you were slated to win.