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KubNation

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  1. REA, if your modification is not a new award or exercising an option period, there is nothing in the FAR prohibiting you as a CO from executing that modification; even if they have a delinquent federal debt. As stated previously, FAR 9.405-1 Continuation of Current Contracts addresses those instances. If your modification were not new work or an option, an auditor has nothing to reference to say you should have checked SAM. Am I not going to execute an admin modification to my contract because the vendor now has an exclusion in SAM? Of course I am, I just won't be able to exercise an option if and when that time comes.
  2. 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.
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