“VERIFY BEFORE YOU CERTIFY” — 3-MINUTE BRIEF, PART 2 OF 4
Part 1 covered what changed. This brief: the three layers contractors certify today.
Recap: Executive Orders 14173 and 14398 replaced the old EO 11246 affirmative-action framework with a certification-based model, enforceable through the False Claims Act. Here’s how that model actually works, layer by layer.
Layer 1 – SAM.gov Representations & Certifications
Every contractor doing business with the federal government must be registered in the System for Award Management (SAM.gov), which requires completing standard Representations and Certifications. This is the baseline, made at registration and renewed periodically, confirming the contractor’s eligibility to hold federal contracts, including nondiscrimination-related representations.
