Class Deviation 2012-O0015
System for Award Management (SAM)

Effective immediately, until further notice, deviation is granted from the initial registration requirements of Federal Acquisition Regulation (FAR) subpart 4.11 and the Defense FAR Supplement (DFARS) 204.1103(2)(i); and the required use of annual representations and certifications per FAR 4.1201 and DFARS 204.1202.

The General Services Administration (GSA) implemented Phase I of SAM on July 29, 2012. It includes the functional capabilities of the retired Central Contractor Registration (CCR), Federal Agency Registration (FedReg), Online Representations and Certifications Application (ORCA), and Excluded Parties List System (EPLS) applications. Since implementation, SAM has experienced performance issues that have affected the timely processing of awards. GSA has been taking aggressive action to resolve these issues promptly. This deviation provides a brief period of time for achieving resolution of the remaining issues, and will remain in effect only until these actions are complete.

Except for awards where the Governmentwide purchase card (GPC) is used as the method of payment, contracting officers shall include the attached clause 52.204-99, System for Award Management Registration, in lieu of FAR clause 52.204-7, Central Contractor Registration, and DFARS 252.204-7004, Alternate A, Central Contractor Registration. The attached clause 52.204-99, System for Award Management Registration, shows changes from FAR clause 52.204-7, Central Contractor Registration, in bold text.

Contractors are required to be registered in SAM prior to submitting invoices. Unless planning to use the GPC as the method of payment -

  • A prospective contractor is not required to be registered in SAM (formerly CCR) prior to award; and
  • Contracting officers are not required to check SAM to ensure registration prior to award.

If planning to use the GPC as the method of payment on a contract, the contracting officer must still check SAM prior to award to ensure that the prospective contractor does not have delinquent Federal debt in accordance with FAR 32.1108.

With regard to use of annual representations and certifications, for the duration of this class deviation -

  • Contracting officers shall include the appropriate individual provisions in solicitations in lieu of FAR 52.204-8, Annual Representations and Certifications, and DFARS 252.204-7007, Alternate A, Annual Representations and Certifications;
  • If offers have already been received, contracting officers may require that the prospective contractor complete the provisions outside out of SAM prior to award. The act of completing the provisions shall be considered clarifications, and not on its own be considered opening discussions; and
  • If the prospective contractor has a copy of its ORCA registration with an expiration date on or after the award date, the contracting officer may accept a complete PDF copy with the expiration date showing as completion of the provisions.

The requirements of FAR 9.405 are not changed. GSA has re-established the EPLS website ( to provide contracting officers the ability to ensure a prospective contractor is not actively excluded from procurement actions.

This class deviation remains in effect until rescinded.

Effective Date: August 21, 2012 (10 years ago)
Expire Date: None Given
Incorporated: July 22, 2013 (9 years ago)
Official Documents: Memo
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