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Government Contractors

Another Delay for SAM?

System for Award Management (SAM) is a federal government database that will eventually combine the data from multiple databases or systems to provide a single portal for contractors, grantees, and federal agencies. In July 2011, eight systems were projected to be included in SAM by the end of 2014. Currently, only four systems, Central Contractor Registration (CCR), Online Representation and Certifications Application (ORCA), Excluded Parties List System (EPLS) and Federal Agency Registration (FedReg) have been combined.

On July 31, 2014, the president issued an Executive Order (Order): Fair Pay and Safe Workplaces. It requires federal contractors submitting an offer for a contract of goods or services exceeding an estimated $500,000 to represent whether the U.S. Department of Labor has rendered certain actions against the offeror. Other contractor reporting requirements related to compliance with labor laws apply after contract award.

The Order directs the Secretary of Labor to work with the Director of Office of Management and Budget (“OMB”) and Administrator of General Services Administration (“GSA”) to improve data collection processes and systems as necessary to meet the data collection requirements, reduce the burden on contractors and increase the amount of information available to agencies. The Order also directs the Director of OMB to work with the Administrator of GSA to include Federal Awardee Performance Integrity Information System (FAPIIS), one of the not yet consolidated databases, information submitted by contractors as required by the Order, including data and the resolution of issues related to the reported information. Further, the Administrator of General Services shall develop a single website for contractors to use for all federal contract reporting requirements related to this order, as well as any other federal contract reporting requirements to the extent practicable.

It appears that GSA will need to create a new database or substantially modify an existing one to collect all the data required by this Order. Of course, these changes must first be made to the Federal Acquisition Regulation, including such things as the documentation that will be required if an offeror/contractor reports that the Department of Labor has rendered one of the specified actions against it. The day will still come, however, when GSA must begin collecting this new data in a way that contracting officers can access it as a part of the contract award and administration processes. The effort put into creating a system to accomplish that would likely use resources that would otherwise be applied to completing the original concept of SAM. For those of us who have been looking forward to completion of SAM so that we can go to one place for everything, it looks like we will be waiting a little longer than expected.

If you have any questions about SAM, contact a member of our GovCon team.

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