In ICE-CO's defense, the majority of DHS-ICE here in DC seems to have this idea that it is required for every contract action, which I thought to be ridiculous when I was given a file audit and said SAM was missing for an admin mod.
I spoke to the internal senior level auditor and requested she show me in the FAR where it is "required" and she cited FAR 52.204-17(b)(1) which states: "(b)(1) By submission of an offer, the offeror acknowledges the requirement that a prospective awardee shall be registered in the SAM database prior to award, during performance, and through final payment of any contract, basic agreement, basic ordering agreement, or blanket purchasing agreement resulting from this solicitation.
She said since it says "during performance", any time we are touching a contract (modification) we should be doing our due diligence to verify their SAM registration is active. Does it hurt? No. But it is definitely not mandatory per the FAR.