Well, some good news.
Back in May, we wrote about a contractor that lost an award because its SAM registration briefly lapsed while the government was evaluating proposals. One day. That was enough under the language being applied at the time.
The government has now addressed that problem.
What Changed?
An interim FAR rule effective November 12, 2024 clarifies the preaward registration requirement. Under the revised FAR 52.204-7, an offeror must be registered in SAM when submitting an offer or quotation and at the time of award.
A lapse between those two points, corrected before award, does not by itself make the offeror ineligible under that provision. The rule specifically addresses the continuous-registration interpretation behind decisions like the one we discussed.
That is welcome breathing room for a small business that has put real time and money into a proposal.
So Can I Let My Registration Expire?
I would not make that your plan.
The change removes a particular preaward trap. It does not remove the two checkpoints. If your registration is inactive when you submit your offer, fixing it later is a different problem. If it is inactive when the agency is ready to award, you have another problem.
And you usually do not control when that second checkpoint arrives. “We thought they would award next month” is not a great renewal strategy.
The revised FAR provision also points contractors to FAR 52.204-13 for the requirement to maintain registration during performance and through final payment. Winning the contract is not the end of your SAM responsibilities.
What Should I Do Differently?
Keep renewing early. That part of our original advice has not changed.
Give someone responsibility for the expiration date, the renewal, and confirming that the record actually shows active status. A submitted renewal is a task in progress; an active registration is the result you need.
When a proposal is going out, check the registration as part of the submission checklist. When an award looks close, check again. Save the confirmation with your proposal records so you are not trying to reconstruct the timeline later.
If a lapse has already happened during an evaluation, read the solicitation and any amendments, including the version of FAR 52.204-7 that applies. Do not assume the new language automatically fixes a procurement conducted under the old provision. Get the registration active and address the actual facts promptly.
A Better Rule. The Same Good Habit.
Our original cautionary tale described a real problem under the earlier language. This change makes the rule more sensible. It still pays to avoid finding out how much flexibility you have when an award is on the line.
If you need help with a SAM registration or renewal, or keeping the administrative side of your government contracting work in order, get in touch.