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The Interim Rule: A Simplified Guide for Government Contractors
Understanding the New SAM Registration Rules
The Federal Acquisition Regulation (FAR) recently introduced an interim rule that aims to simplify the System for Award Management (SAM) registration requirements for government contractors. This change is designed to streamline the process and reduce unnecessary burdens on businesses.
What’s Changing?
The key change introduced by the interim rule is the relaxation of SAM registration requirements between the time of offer submission and contract award. Previously, contractors were required to maintain an active SAM registration throughout this entire period. Now, the rule clarifies that registration is only necessary at the time of offer submission and contract award.
Why the Change?
This change comes in response to a Government Accountability Office (GAO) decision that interpreted the FAR to require continuous SAM registration between offer submission and contract award. The GAO’s interpretation was seen as overly restrictive, as it could lead to the disqualification of qualified contractors for minor registration lapses.
What’s Not Changing?
While the interim rule relaxes certain requirements, it’s important to note that some key aspects remain unchanged:
- Pre-Offer Registration: Contractors must still be registered in SAM before submitting an offer or proposal.
- Post-Award Registration: Contractors must maintain an active SAM registration throughout the contract performance period, including during final payment.
- FAR Clause 52.204-13: This clause, which outlines the specific requirements for SAM registration, remains in effect.
Key Takeaways for Contractors
To ensure compliance with the new rules, contractors should keep the following in mind:
- Timely Registration: Submit your SAM registration well in advance of the offer submission deadline to avoid any processing delays.
- Monitor Registration Status: Regularly check your SAM registration to ensure it remains active.
- Understand FAR Clause 52.204-13: Familiarize yourself with the specific requirements outlined in this clause, as it governs SAM registration during contract performance.
- Stay Updated: Keep an eye on any future updates or changes to the FAR and SAM regulations.
The Bottom Line
The interim rule is a welcome development for government contractors, as it simplifies the SAM registration process and reduces the risk of disqualification for minor lapses. By understanding the key changes and maintaining compliance with the FAR, contractors can streamline their procurement process and focus on delivering quality services to the government.
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