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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!
This is new to me: Contractors have to register with dnb.com for a DUNS number in order to register in SAM, which is required in order to get a government contract. CCR, and now SAM, allow an entity with a single DUNS to add 4-digit suffixes ("DUNS+4") to create multiple accounts within CCR/ SAM for different contracts. DUNS+4 can help businesses segregate funds and manage contracts. A small business was recently contacted by DLA, who assigns CAGE Codes, and was told that they could no longer use the DUNS+4 numbers that they registered in CCR. Each DUNS+4 number gets a separate CAGE Code, and DLA is rationing these Codes - after they were already issued. This SB has a current Kt awarded through CCR using an old DUNS+4, and now has to get the CO to mod the Kt to show their basic DUNS (without the "+4" extension) and corresponding CAGE Code. Separately, they also have an offer pending with a different agency that was submitted using another DUNS+4, and I advised them that they need to notify the PCO to change both DUNS and CAGE. The DUNS+4 and associated CAGE Code that were put on the SF-1449 no longer show up in SAM. Why is DLA doing this ? Are they running low on electrons ?