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ARTICLE · 09 JUNE 2023

Check Your SAM Registration Early And Often

Crowell & Moring LLP
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Federal contractors must be registered on SAM.gov to be eligible for award of federal contracts. Failure to do so can have significant consequences, as the recent U.S. Court of Federal Claims (CFC)...

United StatesGovernment, Public Sector
Robert Sneckenberg
Robert Sneckenberg
Issac D. Schabes
Issac D. Schabes
Allison Skager
Allison Skager
Rachel Schumacher
Rachel Schumacher
Stephanie L. Crawford
Stephanie L. Crawford

Federal contractors must be registered on SAM.gov to be eligible for award of federal contracts. Failure to do so can have significant consequences, as the recent U.S. Court of Federal Claims (CFC) decision in Myriddian, LLC v. United States, No. 23-443 makes clear.

In Myriddian, the Centers for Medicare & Medicaid Services (CMS) awarded a five-year, $11 million contract to Cloud Harbor Economics, LLC (Cloud) for coding support services. Myriddian, an unsuccessful offeror, protested at the CFC, arguing Cloud was ineligible for award under FAR 52.204-7, which provides that an offeror must "be registered in SAM when submitting an offer or quotation, and shall continue to be registered until time of award." Although Cloud was registered in SAM at the time of proposal submission and at the time of contract award, Cloud's registration had lapsed for three weeks during the proposal evaluation period. The CFC sustained the protest, holding that FAR 52.204-7

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