What’s new in Federal Contracting?
Key Considerations When Subcontracting with a Federal Government Contractor
Federal procurement contracts can be a lucrative line of revenue for many businesses. But deals between private entities and the government are intensely regulated and raise myriad issues not found in traditional commercial settings. Importantly, these unique challenges are not limited to prime contractors. Subcontractors, too, are bound by some of the legal and contractual obligations that govern these procurements. The result is that private parties working on government projects end up with commercial agreements that include elements of public contract law. To read more about this, click here. [April 2023]
OFCCP Notification to federal contractors to certify through the Contractor Portal by June 29, 2023
The Office of Federal Contract Compliance Programs (OFCCP) will open its Contractor Portal on March 31, 2023, for existing covered federal contractors to certify compliance with Affirmative Action Program (AAP) requirements for this year. Covered federal contractors and subcontractors must use the Contractor Portal to certify, on an annual basis, whether they have developed and maintained an AAP for each establishment and/or functional/business unit, as applicable. For 2023, existing covered contractors must certify their compliance through the Contractor Portal between March 31 – June 29, 2023. The Contractor Portal’s certification feature has been enhanced and contractors must now provide the start date of their AAP Coverage Period when certifying. Click here to read more. [March 2023]
Biden’s $842B Pentagon Budget Proposal Would Boost New Weapons
The Biden administration is proposing a $842 billion Pentagon budget for 2024 that boosts spending on new drones, combat jets, hypersonic missiles, and submarines. The spending plan, announced on Thursday, highlights how Pentagon’s priorities are shifting in response to China’s weapons developments. Pentagon officials are expected to hold briefings about the 2024 spending plan on Monday, when more detailed budget justification documents are sent to Congress. Click here to read more. [March 2023]
A Change in SAM.gov will Affect Access for Some Entity Administrators
Beginning March 3, 2023, Entity Administrator roles can only be held by employees, officers, or board members of the organization. A comprehensive role with elevated responsibilities, this change to the Entity Administrator role ensures the entity is in control of and accountable for who can update their registration in SAM.gov, while allowing entities to continue to use service providers to manage their entity registration, if they wish. If you use an outside service to manage your registration, or if you provide registration management services to other organizations, this change to SAM.gov roles may impact you. The outside service and/or the entity may need to take action to ensure entities can manage access to their entities. Click here to read more. [February 2023]
Supply Chain Mapping Initiative
The Defense Logistics Agency (DLA) has partnered with N-Tier Illumination (TM) to better understand potential supply chain vulnerabilities and develop risk mitigation strategies. N-Tier Illumination (TM) is a secure, commercial supply chain discovery and risk management tool that helps organizations understand key relationships across their supply chain. Supply chain mapping is a new requirement for DLA. The National Defense Authorization Act (NDAA) for FY2022, Section 841-10 USCA ? 2509, requires DOD to streamline and digitize its approach for identifying and mitigating risks to the defense industrial base. To learn more about this new initiative, click here. [November 2022]
DoD Issues Deviation After Continued UEI Transition Delays
Because of the delays that have been happening with the transition to the new unique entity identifier (UEI) on SAM.gov, the Defense Department isn’t requiring contractors to have a new number to do business with them for the next six weeks. The Defense Pricing and Contracting office issued a deviation to the Federal Acquisition Regulation (FAR) on Sept. 8 that allows the services and defense agencies to do business with companies who aren’t fully registered in the governmentwide acquisition system. DoD says contracting officers can move forward without a finalized SAM.gov registration through Oct. 31. To read more about this, click here. [September 2022]
New Business Size Standards
The U.S. Small Business Administration has released new business size standards. These standards are effective May 2, 2022. To review the list based on NAICS code designation, please click here. [May 2022]
SAM Registration and Unique Entity ID (UEI)
On April 4, 2022, the Federal Government Contracting Community switched from the DUNS number to the Unique Entity ID (UEI). DUNS numbers will no longer be used and will not be visible on the SAM.gov website. Businesses can locate their new 12 alpha numeric ID in SAM. Contact WPI if you need assistance in locating your UEI. It is also recommended not to throw away your DUNS number yet as some agencies may need additional time to make the change to the UEI number. [April 2022]
The Unique Entity ID is here! Here’s What You Need to Know
As of April 4, the Unique Entity ID from SAM.gov is now the authoritative identifier for those doing business with the federal government. The DUNS Number is no longer valid for federal award identification.
All of the Integrated Award Environment (IAE) systems — SAM.gov, eSRS, FSRS, FPDS, FAPIIS, and CPARS, as well as all other GSA systems — are now only using the Unique Entity ID to identify entities.
The Unique Entity ID is generated in SAM.gov. If you are registered in SAM.gov (active or not), you already have a Unique Entity ID. It is viewable at SAM.gov. If you are new to SAM.gov and will be registering for the first time, you will get your Unique Entity ID (SAM) during registration.
Here is a snapshot of what’s new at SAM.gov as of April 4, 2022:
- The DUNS Number has been removed and the Unique Entity ID is now the identifier of record for all entities in IAE systems.
- SAM.gov generates the Unique Entity ID, which will be used in federal award systems.
- SAM.gov searches, contract data, ad hoc reports, Application Programming Interfaces (APIs), and extracts use the Unique Entity ID. You will no longer find the DUNS number in any SAM.gov searches, views, or extracts.
- Entities now make updates to their legal business name and physical address through SAM.gov. Once you select “Create Incident” through the update entity information workflow, you will monitor the status of your ticket in your SAM.gov Workspace or in the Federal Service Desk (gov) instead of going to Dun & Bradstreet.
- Entities registering for the first time will be assigned a Unique Entity ID as part of the registration process.
Entities now update their entity information for federal award purposes through their SAM.gov Workspace. You will need to validate your entity information in SAM.gov when renewing your registration or changing your legal business name or address. Learn how to update your entity information here.
Entities that are prime awardees reporting on sub-awardees in FSRS should use the sub-awardee’s Unique Entity ID . You can search SAM.gov for another entity’s information.
Those new to SAM.gov can register their entity or just get a Unique Entity ID by signing in to SAM.gov and selecting Get Started. If you want to bid directly on contracts or grants from the federal government, choose “Register Entity.” If you are a sub-awardee that just needs a Unique Entity ID for subaward reporting, choose “Get Unique Entity ID.”
Remember, the transition from DUNS Number to Unique Entity ID does not affect CAGE codes.
Use SAM.gov data:
SAM.gov APIs and extracts will now use the Unique Entity ID. If they contain the fields for DUNS Numbers, but the fields will be empty.
If you discover your saved searches aren’t returning information as expected, please make sure you have replaced your DUNS Number fields with Unique Entity ID fields.
If your contract data ad hoc reports do not work as expected, please make sure you have replaced your DUNS Number fields with the Unique Entity ID fields.
For additional information, please contact Marc Violante at firstname.lastname@example.org or 920-456-9990.
Don’t have a Unique Entity ID yet? Here’s how to get one.
Learn more about the Unique Entity ID here.
SAM Planned Maintenance Schedule
SAM.gov will undergo scheduled maintenance on Tuesdays, Thursdays, and Fridays from 7:00 pm CT – 10:00 pm CT. During these maintenance windows, access to the site may be intermittent or disrupted. [April 2022]
For additional information on these topics, please contact our staff of experts at ApexAccelerator@wispro.org or 414-270-3600.