DoD Issues Deviation for SAM Registration Requirement Due to Ongoing Processing Delays

Crowell & Moring – On September 8, 2022, the Department of Defense issued Class Deviation 2022-O0009 immediately authorizing contracting officers to allow active registration in the System for Award Management (“SAM”) within 30 days of contract award or three days prior to submission of the first invoice (whichever comes first) rather than at the time of award—provided the contractor can prove it has initiated or attempted to start the SAM registration process.  The Deviation is in effect through October 31, 2022 unless rescinded or extended.