System for Award Management
SAM registration with a valid unique entity identifier is mandatory for offer submission and award, and delays can jeopardize contract eligibility.
Overview
FAR 52.204-7, System for Award Management (SAM), requires all offerors to be registered in SAM when submitting an offer or quotation and at the time of award. Registration involves providing detailed business information, including a unique entity identifier, EFT indicator (if applicable), and completion of required sections in SAM. The Government validates all mandatory data, including the Taxpayer Identification Number (TIN), and marks the record as "Active" before an offeror is considered registered. If an offeror does not have a unique entity identifier, they must obtain one through the designated entity at www.sam.gov. The provision also outlines the information required to obtain a unique entity identifier and emphasizes the importance of allowing sufficient processing time for registration. Alternate I allows for delayed registration in certain circumstances, requiring registration as soon as possible or before award.
Key Rules
- Mandatory SAM Registration
- Offerors must be registered in SAM at offer submission and award, with all required information validated and the record marked "Active."
- Unique Entity Identifier Requirement
- Offerors must provide their unique entity identifier and EFT indicator (if applicable) on the offer cover page.
- Obtaining a Unique Entity Identifier
- Offerors without a unique entity identifier must obtain one from the designated entity at www.sam.gov, providing specific business information.
- Processing Time
- Offerors should account for registration processing time and begin registration immediately upon solicitation receipt.
- Alternate I Provision
- In certain cases, registration may occur after offer submission but must be completed before award.
Responsibilities
- Contracting Officers: Must verify offeror SAM registration and unique entity identifier before award.
- Contractors/Offerors: Must register in SAM, provide accurate information, obtain a unique entity identifier, and maintain active status.
- Agencies: Oversee and validate registration data, including TIN validation with the IRS.
Practical Implications
- This provision ensures all contractors are properly identified and validated before contract award, supporting transparency and secure payment processes. Delays in registration can jeopardize award eligibility, so timely action is critical. Common pitfalls include incomplete registration, mismatched entity information, or failure to maintain active status in SAM.