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I am a recently Warranted CO at a civilian Bureau only working in the states (not overseas) that deals with a lot of very low dollar requirements between the Micro Purchase Threshold (MPT) and $15k. I also have to run the purchase card program, but that's an entirely different headache. I currently have an ~$11,000 tree removal project that does not count as unusual and compelling urgency. The only capable vendor, according to the requiring office, is not in SAM. My question is: for things under the $15k threshold, with no synopsizing or publicizing required, and with only oral quotations, and with an attempt to innovate, keep documentation minimal, and be maximally efficient (IAW FAR 13), is there any way to use a non-SAM-registered vendor? I am trying to figure out if there is a way to use purchase card, too, because logically, we are given these tools (Warrants, training, purchase cards, FAR 13, etc) for exactly this reason: to not spend hours and hours on low risk, low dollar, low priority awards. Could one simply have a vendor manually fill out 52.212-3 to get their representations in writing? 52.204-7 System for Award Management, as prescribed at 4.1105(a)(1), must go in "all solicitations" - and it looks like the only real exception an exception under 4.1102(a)(5): Somewhat tangential: these MPT - $15k projects can be very frustrating and time consuming, particularly because the administrative costs are so high relative to other work we have to do, and requiring offices insisting we use "their" "local" vendor who they often talk with for weeks before we get a PR. Being able to streamline and simplify the 100+ requirements like this that we deal with each year would save us hundreds of hours of work.
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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!
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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 ?
