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Having worked at three different (Army) contracting offices, my experience has been that, frequently, prior to award of any contract action (new contract, modification, task order, etc.), the Contracting Officer requires that a contractor's SAM registration be validated, not only for exclusions, but also to verify their registration is active.  Upon a close read of FAR 4.1103, DFARS 204.1103, FAR 52.204-7 SAM, and FAR 52.204-13 SAM Maintenance, I left wondering if it's necessary to validate SAM registrations prior to issuing existing task orders. 

FAR 4.1103(a)(3) states the Contracting Officer need not verify SAM registration before placing an order or call if the contract or agreement includes the provision at 52.204-7 or at 52.212-1. 

If the contract includes either of those provisions, then it will also include the clause at 52.204-13 or 52.212-4, which require SAM record maintenance.

DFARS 204.1103(2) states that except for unilateral administrative mods, the the Contracting Officer shall ensure that the contractor's record is active in SAM. 

When reading these regulations together, I'm tempted to conclude that, if an IDIQ ("D") contract has 52.204-7 or 52.212-1 and 52.204-13 or 52.212-4, then the PCO should validate the SAM registration before exercising the D contract option.  But there's no mandatory requirement to check for all IDIQ orders (or by extension, mods to orders).

Any thoughts?  What am I missing here?

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2 hours ago, justinramani said:

Check out Part 9: Contractor Responsibility - then check the AFARS.

I appreciate that, @justinramani. But I'm not sure you answered my question. Or perhaps I mis-presented it.  Part 9 is Contractor Qualifications. Do you mean FAR Subpart 9.1 Responsible Prospective Contractors, because that's where "Contractor Responsibility" is principally addressed?  Or Subpart 9.4 Debarment, Suspension, and Ineligibility? Because AFARS 5109.405(d)(1) is where the Army's agency regulation states that "Contracting Officers shall review the SAM Exclusions... immediately prior to... placement of a new purchase or task or delivery order." 

I ask because I understand the implications of "exclusions" and the related requirements, however for this question I'm interested in whether or not there's a firm regulation to state that the Contracting Officer must validating that a contractor with an IDIQ has appropriately maintained their SAM registration before considering them for a task order award.  

I'm still left leaning toward the interpretation that a Contracting Officer is explicitly REQUIRED to validate the SAM registration before exercising the D contract option (per DFARS 204.1103(2)). But the Contracting Officer is PERMITTED to not validate that the Contractor has active SAM registration (per FAR 4.1103(a)(3)) before issuing an order under that same D contract.  And yes, the (Army) Contracting Officer must verify that the contractor does not have an active record of SAM exclusions, regardless of whether its registration is active or not (per AFARS 5109.405(d)(1)).

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