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Hello! I thought this would be a good question for this forum to get a good idea on how things are done in other agencies. How often do you check the System for Award Management (SAM) for active exclusions? Do you check it for every contract action? That is how I was trained but someone brought up today that this may not be necessary. The FAR prohibits soliciting, or awarding to vendors that are on the excluded parties list but does not specifically require the Contracting Officer to check for every modification (e.g. admin changes). I found two applicable references which are verbose but nothing specific to requiring the check for every contract action - FAR 4.11 and 9.404-9.405: FAR 4.1103(a)(1) says that the Contracting Officer "(1) Shall verify that the prospective contractor is registered in the SAM database before awarding a contract or agreement. Contracting officers are encouraged to check the SAM early in the acquisition process, after the competitive range has been established, and then communicate to the unregistered offerors that they shall register;" FAR 9.404(c)(7) says that each agency must "(7) Establish procedures to ensure that the agency does not solicit offers from, award contracts to, or consent to subcontracts with contractors whose names are in the SAM Exclusions, except as otherwise provided in this subpart;" I'm at the Dept of Homeland Security. I can't find any agency specific information to requiring a check for every contract action either. Do you think this is something that was passed down as a best practice but not a requirement? This could also adversely affect a CO if they award a modification and find out that a vendor has been suspended so it could result in more dire consequences. I would love to know what you think!
