Make Sure Your SAM Profile is Current, Complete, and Accurate

We've heard of companies - contractors and prospective contractors - who give short shrift to the accuracy of data submitted to SAM (System for Award Management). Everyone knows that you need to be SAM registered in order to be considered for award. SAM can be confusing and even intimidating for some. If you can somehow plow through the many layers of data, representations, and certifications and be presented with "completed", you might consider yourself a victor. The question is, did you get everything right? Did you enter the correct NAICS codes? How about socio-economic status? One might be tempted to think, made it through, close enough, good to go.

A recent Comptroller General (GAO) bid protest decision underscores the importance of making certain your information is accurate, current, and complete. Nationwide Value Computer (Nationwide) protested a Navy award to a competitor alleging that it had the lowest price and should have received the contract. The solicitation was a small-business set-aside acquisition.

The Navy, in evaluating the offers, consulted Nationwide's SAM profile and found that Nationwide had certified itself as a non-small-business. As a result, the Navy disqualified Nationwide from the procurement. Nationwide objected to the Navy's determination that it was not an eligible small business concern. Nationwide noted that its Dun and Bradstreet listing noted its small business status.

Since the record reflects that at the time the Navy checked SAM, Nationwide had affirmatively represented that it was not a small business, the GAO had not basis to conclude that the Navy acted unreasonably when it eliminated Nationwide from the competition on the basis that it was not a small business.

SAM will prompt administrators to update their profiles once per year. It may be advisable for companies to establish procedures to update their profiles more frequently.