ARTICLE · 28 NOVEMBER 2024

FAR Council Nixes Continuous SAM Preaward Registration Requirement

Reed Smith

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Federal Acquisition Regulation (FAR) Council issues interim rule clarifying that companies competing for federal contracts must be registered in System for Award Management (SAM) only at proposal submission.

United StatesGovernment, Public Sector

Kendra Perkins Norwood

Karla V. Perez Chacon

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Key takeaways

Federal Acquisition Regulation (FAR) Council issues interim rule clarifying that companies competing for federal contracts must be registered in System for Award Management (SAM) only at proposal submission and contract award
Continuous SAM registration is no longer required to be eligible for award
Interim rule provides relief from harsh consequences of previous requirement, which made offerors ineligible after even a one-day lapse in SAM registration

Overview of interim rule

The FAR Council has issued an interim rule amending FAR 52.204-7(b)(1) to clarify SAM pre-award registration requirements. FAR 52.204-7(b)(1) formerly required offerors to continuously maintain an active SAM registration throughout the period between proposal submission and contract award to be eligible to receive the award. The U.S. Court of Federal Claims and the Government Accountability Office both strictly enforced this previous requirement, often determining

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This article is presented for informational purposes only and is not intended to constitute legal advice.

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