News & Analysis as of

System For Award Management (SAM)

Miles & Stockbridge P.C.

Executive Order Aims to ‘Restore Common Sense’ in Procurement by Reforming the Federal Acquisition Regulation

Yogi Berra once said, “The future ain’t what it used to be.” Those who have spent a career in federal procurement have seen many cycles of well-intentioned procurement reform instead create a system that is more complex,...more

Morrison & Foerster LLP - Government...

Bid Protest Spotlight: Registration, Substantiation, Experience

To kick off the new year, this bid protest spotlight highlights two U.S. Government Accountability Office decisions involving System for Award Management (SAM) registration requirements when submitting an “offer” and an...more

Blank Rome LLP

GAO Rejects Notion of a Pre-FPR “Continuous Registration Requirement” for SAM

Blank Rome LLP on

The last week saw GAO sustain two protests that should put the nail in the SAM “continuous registration” coffin. The Federal Acquisition Regulatory (“FAR”) Council recently revised the standard System for Award Management...more

McCarter & English Blog: Government Contracts...

They Did It. They Really Did It! The Arrival of the FAR CUI Proposed Rule

After years of anticipation, the Federal Acquisition Regulation (FAR) Council has announced the arrival of its proposed rule to enhance the safeguarding of Controlled Unclassified Information (CUI) in federal contracts (the...more

McCarter & English Blog: Government Contracts...

What Happens When Uncle Sam Doesn’t Understand SAM? The Case of the Lucky Protester . . .

On January 8, 2025, in UNICA-BPA JV, LLC, the U.S. Government Accountability Office (GAO) sustained a protester’s challenge to its elimination from the competition for failing to have an active System for Award Management...more

Bass, Berry & Sims PLC

Bid Protest Minute: GAO Decision Clarifies SAM Registration Rule

Bass, Berry & Sims PLC on

On January 8, the Government Accountability Office (GAO) sustained a pre-award bid protest filed by Bass, Berry & Sims PLC (Bass Berry), which challenged the Federal Law Enforcement Training Centers’ (FLETC or the Agency)...more

Cohen Seglias Pallas Greenhall & Furman PC

Changes to the Suspension and Debarment Rules in 2025

A contractor who is proposed for debarment is effectively debarred as soon as the notice letter is received. It is like being sentenced before trial and it can take weeks, or months, for the contractor to convince the...more

Wiley Rein LLP

FAR Council Issues Long-Awaited Final Rule to Harmonize (Almost) Procurement and Nonprocurement Suspension and Debarment Rules

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WHAT: On January 3, 2025, the Federal Acquisition Regulation (FAR) Council published its final rule to amend the FAR to improve consistency between the procurement and nonprocurement rules on suspension and debarment. The...more

Miles & Stockbridge P.C.

Interim Rule Clarifies Requirements for Registration in System for Award Management

Miles & Stockbridge P.C. on

The Federal Acquisition Regulatory (FAR) Council issued an interim rule earlier this month revising FAR 52.204-7 to require offerors to be registered in System for Award Management (SAM) at two points in time: “[1] when...more

Morrison & Foerster LLP - Government...

Bid Protest Spotlight: Unclear Criteria, Data Rights, Conflicts

This month’s Bid Protest Roundup highlights three recent protests: one from the U.S. Government Accountability Office and two from the Court of Federal Claims. The first protest concerns an agency using unstated evaluation...more

Maynard Nexsen

FAR Council Issues Interim Rule Removing SAM.gov Registration Continuity Requirement

Maynard Nexsen on

On November 12, the Department of Defense, General Services Administration, and the National Aeronautics and Space Administration (together, the "FAR Council") issued an interim rule, effective November 12, 2024, to amend the...more

Wiley Rein LLP

FAR Council Issues Interim Rule Prohibiting Procurement and Operation of Certain Unmanned Aircraft Systems

Wiley Rein LLP on

WHAT: On November 12, 2024, the Federal Acquisition Regulatory Council (FAR Council) issued an interim rule amending the FAR to implement the statutory prohibition on procurement and operation of unmanned aircraft systems...more

Wiley Rein LLP

SAM Registered I Am Part 3: A Journey Through the Recent Case Law, Practical Tips and Guidance for Registering in SAM, and...

Wiley Rein LLP on

We have actively monitored the drum beat of bid protest decisions addressing lapses in an offeror’s System for Award Management (SAM.gov or SAM) registration and their impact on an offeror’s eligibility for award. More recent...more

Maynard Nexsen

GAO Decision Shows that Even a 1-Day Lapse in SAM Registration Can Sink Your Bid

Maynard Nexsen on

As many government contractors know all too well, doing business with the government requires contractors to become familiar with and adhere to countless rules and regulations governing the procurement process. As shown in a...more

Bradley Arant Boult Cummings LLP

SAM Registration Lapse Can Now Cost You a Contract Award

The Government Accountability Office (GAO), in TLS Joint Venture, LLC, B-422275, recently sustained a bid protest alleging that the contract awardee’s System for Award Management (SAM) registration lapsed between the...more

Fox Rothschild LLP

Procrastination Has Consequences: How Waiting Until the Last Minute to Renew Their SAM Registration Cost a Contractor Millions

Fox Rothschild LLP on

The Government Accountability Office (“GAO”) recently sustained a protest of a contract award because the winning contractor failed to maintain their System for Award Management (“SAM”) registration from the date their...more

Miles & Stockbridge P.C.

Recent GAO Decision Requires Continuous Registration in the System for Award Management for Government Contract Award Eligibility

Companies competing for federal contracting opportunities now have yet another reason to fear their proposals being rejected and their awards getting overturned....more

Baker Donelson

OMB Soon To Release Updates To Uniform Grant Regulations

Baker Donelson on

The Office of Management and Budget (OMB) held a webinar on April 4, 2024, which was followed by a White House announcement of the impending launch of revised regulations at Title 2 of the U.S. Code of Federal Regulations (2...more

Wiley Rein LLP

SAM (Registered) I Am Part 2: Contractors, Beware of Lapses in SAM Registration

Wiley Rein LLP on

WHAT: The Government Accountability Office (GAO) sustained a disappointed offeror’s protest alleging that a solicitation’s inclusion of FAR 52.204-7 required the awardee to be found ineligible because its System for Award...more

Seyfarth Shaw LLP

FAR Council Proposes Revisions to Suspension and Debarment Rules

Seyfarth Shaw LLP on

Suspension and debarment are among the most powerful administrative remedies the Government has at its disposal to address non-compliance with laws and regulations, and to protect the Government’s business interests....more

Wiley Rein LLP

FAR Council Proposes Changes to Harmonize Procurement and Nonprocurement Suspension and Debarment Rules

Wiley Rein LLP on

WHAT: On January 9, 2024, the Federal Acquisition Regulation (FAR) Council published a proposed rule to amend the FAR to improve consistency between the procurement and nonprocurement rules on suspension and debarment. The...more

Wiley Rein LLP

Interim Rule Requires Contractors to Secure Supply Chains Involving Covered Articles and Sources Subject to FASC Exclusion and...

Wiley Rein LLP on

WHAT: A new interim rule prohibits contractors from delivering or using covered articles and sources that are subject to exclusion or removal orders issued under the Federal Acquisition Supply Chain Security Act of 2018...more

Wiley Rein LLP

OMB Proposes Widespread Changes to Guidance on Grants and Agreements

Wiley Rein LLP on

WHAT: On October 5, 2023, the Office of Federal Financial Management, Office of Management and Budget (OMB) issued a proposed rule to revise sections of OMB Guidance for Grants and Agreements. The changes under the proposed...more

Constangy, Brooks, Smith & Prophete, LLP

Contractors! Do you have your UEI?

Unique Entity ID replaces DUNS in EEO-1 Report. As we previously reported, the Equal Employment Opportunity Commission made some material changes to the EEO-1 Report. One of these changes mandates that federal...more

Benesch

GSA/DoD Transportation Law Primer

Benesch on

Many government agencies accomplish their critical missions by using private transportation and logistics services. The General Services Administration (GSA) is often the key federal agency for managing private procurement of...more

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