STEP 4
REGISTRATION AND ELIGIBILITY ISSUES
The majority of the registration and eligibility issues are caused from a lack of knowledge and knowing what the government really need from you to validate your business. These problems create confusion around you being able to register your company correctly in SAM.gov and getting approved, being eligible and responsible for receiving federal government contracts to do business with the government.
Registration is required for entities that want to do business with the government directly and bid on federal government contracts or apply for federal assistance. Registration is "Free" and once registered a government Unique Entity ID (UEI) number is automatically generated and assigned to your business. Your company registration and renewal is every 365 days. If you don't complete the free registration renewal your company will be deactivate.
COMMON REGISTRATION AND ELIGIBILITY ISSUES
1. Business information does not match government records
Your legal business name, physical address, taxpayer information, and other identifying information need to be consistent with the underlying government records. A mismatch can create validation problems or delay activation.
This is particularly important when a business has recently:
- Changed its legal name
- Changed its address
- Formed a new entity
- Changed ownership or structure
- Obtained a new EIN
- Used a DBA instead of its legal entity name
2. The business is not actually ready to register
A company may have been formed with the state but still lack information needed to complete its SAM registration. SAM.gov registration process requires substantial entity information, so businesses should gather their business identity information before starting.
3. Exclusion or debarment issues
SAM.gov contains federal exclusion records. Certain exclusion types can restrict an individual or organization from receiving federal contracts, grants, or other covered transactions.
This makes checking SAM.gov exclusion information an important part of understanding eligibility.
4. The company cannot demonstrate responsibility
An active SAM registration by itself does not guarantee that a company will receive a federal contract.
Under FAR 9.104-1, a prospective contractor generally must demonstrate factors including adequate financial resources, the ability to meet the required schedule, a satisfactory performance record, satisfactory integrity and business ethics, appropriate organization and technical capabilities, and necessary equipment and facilities.
This distinction is important:
SAM registration = ability to participate in the federal award system.
Responsibility = whether the government determines the contractor is capable and qualified for a particular award.
5. Registration is inactive or expired
SAM.gov says an entity must renew its registration every 365 days to keep it active. Businesses should not wait until they are preparing a proposal to discover that their registration has expired.
6. Incorrect or incomplete registration information
Incorrect NAICS codes, representations and certifications, ownership information, points of contact, banking information, or other registration data can create problems later.
Businesses should treat their SAM registration as an important government record not simply as a one-time application.
7. Past performance or responsibility concerns
Federal agencies can consider a contractor's performance record when making responsibility determinations. FAR 9.104-3 addresses how performance and the ability to obtain necessary resources are considered.
A new company, however, should not automatically assume that having little or no federal contracting history makes it ineligible. FAR 9.104-1 specifically states that a contractor should not be found non-responsible solely because it lacks relevant performance history, subject to the applicable rules.
The FAR, it is essentially the U.S federal government's main rulebook for buying goods and services from private companies. Learn more on FAR