DOE Class Deviation Gives COs Leeway on Determining Validity of SAM Registrations

In this class deviation, the Department of Energy provides that contracting officers may make a reasonable determination in documenting the validity of SAM registrations at the time of offer or quotation submission and at the time of award.

In 2018, FAR 52.204-7(b)(1) was revised to state that an offeror is required to be registered in SAM when submitting an offer or quotation and shall continue to be registered until time of award, during performance, and through final payment of any agreement. However, this clause does not prescribe an outcome for failing to comply with SAM continuous registration requirement until the time of award.

To ensure the efficiency of the procurement system through this Class Deviation, the SAM continuous registration requirement is removed from FAR 52.204-7. The Contracting Officer will have the authority to make a reasonable determination in documenting the validity of SAM registrations at the time of offer or quotation submission and at the time of award. This alleviates any need to ensure compliance with the text stating, “continue to be registered until award”.

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