Blog Tags - Sam.gov

The DCMA-enforced CPSR requirement that contractors check sam.gov prior to subcontract award has always bothered me. Not because it's not a good business practice, but because contractor sam.gov checks are not a requirement per FAR Part 52.209-6. Because debarment is a public law, a DCMA finding of noncompliance with the (imaginary from a regulatory perspective) sam.gov requirement can lead to system failure without additional findings. 

The first is for all offerors prior to RFQ issuance; the second within 15 days before award on the awardee only. Couple of things here. If you don't pull before RFQ, you should start. But so far not pulling prior to RFQ is not a major system deficiency, more a "best practice" recommended by DCMA during a CPSR (so don't sweat it too much if you're coming up on a CPSR and you've only got one in the file prior to award).

To caveat - that is a "risk" of a write-up, not a guarantee and hopefully not a significant finding. But the CPSR teams do want to see a pull within a reasonable time frame prior to award. Which I don't think is particularly unfair. Suspension status (in particular) can change in 24 hours and an EPLS pull is probably the easiest public law compliance out there next to timely DPAS acknowledgement on a subcontract.