Earl830 Posted April 3, 2018 Report Share Posted April 3, 2018 I have a question regarding the frequency and timing of when contractors are required to update their SAMrecord. Specifically, when are contractors required to provide the previous fiscal year’s “Total Receipts”. Are contractors required to update their SAM record with Total Receipts once financial results are known, or are contractors compliant if they do not provide this information until their current registration expires? I asked this question to the SAM help desk and this is their response It is recommended that updates be made as soon as possible once the information is known. As long the record remains in active status an entity is in compliance in terms of the SAM record itself. It seems odd that you can be compliant if you've delayed posting this information once it is known so if anyone can provide a citation of where I can find this answer would greatly appreciate the help. Thanks. Link to comment Share on other sites More sharing options...
joel hoffman Posted April 3, 2018 Report Share Posted April 3, 2018 How’s that for an example of Doublethink? Link to comment Share on other sites More sharing options...
Neil Roberts Posted April 3, 2018 Report Share Posted April 3, 2018 3.9.3 of the SAM Guide https://www.sam.gov/sam/SAM_Guide/SAM_User_Guide.htm#Yourresponsibilities "You are responsible for updating all of your registration information as it changes… · You must renew and revalidate your registration at least every 12 months from the date you previously registered to maintain an active status in SAM. However, you are strongly urged to revalidate your registration more frequently to ensure that SAM is up-to-date and in sync with changes (such as an address change) that may have been made to your D&B or IRS information. If you do not renew your registration, it will expire. An expired registration will affect your ability to receive contract awards or payments, submit assistance award applications via Grants.gov, or receive certain payments from some Federal Government agencies. Please be aware that some federal contracts or assistance awards may require you to revalidate your registration more frequently than every 12 months. Please review the terms and conditions of your federal award carefully to ensure what is required to be compliant." If you do not re-validate when critical information changes, and the non current information is relied on by another party to their detriment, on a worst case basis, you should be able to dream up some potential liability there, especially financial information. Link to comment Share on other sites More sharing options...
Neil Roberts Posted April 3, 2018 Report Share Posted April 3, 2018 You may also wish to consider FAR 9.406-2 Causes for Debarment (a)(3) and (c) for non updated serious information Link to comment Share on other sites More sharing options...
Guest Vern Edwards Posted April 4, 2018 Report Share Posted April 4, 2018 20 hours ago, Earl830 said: Specifically, when are contractors required to provide the previous fiscal year’s “Total Receipts”. Are contractors required to update their SAM record with Total Receipts once financial results are known, or are contractors compliant if they do not provide this information until their current registration expires? (Emphasis added.) See FAR 52.204-13, System for Award Management Maintenance (OCT 2016), for the statement of a contractor's legal obligations in that regard. Link to comment Share on other sites More sharing options...
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