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ARTICLE · 12 NOVEMBER 2024

A Common-Sense Change To The Continuous SAM Registration Requirement At FAR 52.204 7

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On November 12, 2024, the Department of Defense (DoD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA) will issue an interim rule amending FAR 52.204-7...

United StatesGovernment, Public Sector
John E. McCarthy Jr.
John E. McCarthy Jr.
Anuj Vohra
Anuj Vohra
Robert Sneckenberg
Robert Sneckenberg
Stephanie L. Crawford
Stephanie L. Crawford
Zachary Schroeder
Zachary Schroeder
Issac D. Schabes
Issac D. Schabes

On November 12, 2024, the Department of Defense (DoD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA) will issue an interim rule amending FAR 52.204-7 to clarify that an offeror's failure to maintain System for Award Management (SAM) registration during the period between proposal submission and contract award does not render the offeror ineligible for award. Providing welcome relief to agencies and contractors alike, the interim rule requires only that an offeror be registered in SAM at the time of offer submission and at the time of contract award.

The interim rule comes in response to Court of Federal Claims (COFC) and GAO decisions that have strictly enforced the language of FAR 52.204-7 stating that "[a]n Offeror is required to be registered in SAM when submitting an offer or quotation and shall continue to be registered until time of award" and required contractors to maintain active SAM registration throughout

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