In order to avoid delays in “the timely processing of awards,” the U.S. Department of Defense (DoD) has ordered the temporary suspension of rules requiring vendor registration in the System for Award Management (SAM).
SAM replaced Central Contractor Registration (CCR), the government’s long-standing vendor database. SAM was launched during the last weekend in July 2012 when CCR vendor data was migrated to the new system.
SAM’s late July implementation included not only CCR but Federal Agency Registration (FedReg), the Online Representation and Certification Application (ORCA), and the Excluded Parties List System (EPLS) as well. “Performance issues” involving the new SAM database prompted DoD’s action to suspend for “a brief period” the requirement that vendors be registered in SAM before being eligible for a contract award.
Since SAM’s launch there have been widespread reports and complaints from vendors and contracting officers alike that they cannot access vendor records or are experiencing slow performance within the on-line system. The General Services Administration (GSA) is responsible for SAM. GSA contracted with IBM to manage the design and implementation of SAM.
In the August 21, 2012 order to temporarily suspend SAM registration requirements, DoD noted that the action would provide “a brief period of time for achieving resolution of the remaining [performance] issues.”
DoD notes that “GSA has been taking aggressive action to resolve these issues promptly.” Earlier news reports indicated that GSA issued IBM a “letter of concern” on Aug. 7. In the official notice, GSA told IBM to develop a plan of action and milestones for how they will make SAM work more smoothly. GSA hired IBM under an eight-year, $74.4 million contract in 2010.
DoD’s order was issued in the form of a “class deviation” which allows the department to suspend Federal Acquisition Regulation (FAR) and Defense FAR Supplement (DFARS) requirements pertaining to vendor registration and annual representations and certifications.
In its order DoD notes that contractors are still required to be registered in SAM prior to submitting invoices.
Before the DoD order, all contractors were required to be registered in SAM, and all contracting officers were required to check SAM before making a contract award.
Until SAM is functional, DoD’s contracting officials are directed to obtain paper or electronic copies of vendors’ representations and certifications in lieu of accessing this documentation via that portion of SAM that used to be the stand-alone ORCA system.
The EPLS migration to SAM has been reversed, thus restoring that website as a site operating on its own. Because of this action, contracting officers once again have the ability to conduct pre-award checks in EPLS to ensure prospective contractors are not on the list of entities excluded from federal contracts.
DoD’s class deviation remains in effect for an indefinite period of time until rescinded.
The SAM User Guide can be downloaded at: https://www.sam.gov/SAMPortal/img/Download-PDF.png.
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August 24, 2012 – 5:33 am EST