2016 Saw More Registration and Schedule Changes Than Ever Before

document-management-compliance-300x231In June 2016 alone, the General Services Administration (GSA) made 77 client-facing enhancements and changes to the System for Award Management (SAM), including seven revisions to FAR subpart 4.18, FAR 52.204-17, FAR 52.204-3, and FAR 52.212-3.

These changes affected the type of information a company must submit when completing a SAM Registration. For companies with current SAM Registrations at the time these regulation changes went into effect, the SAM Registration had to be updated to remain in compliance. We did this for each of our clients, because one of the several benefits of working with US Federal Contractor Registration is knowing that we remain on top of all changes that may affect a client’s SAM Registration and address these changes as they come up.

Ownership Details Core Data

  • Include information about a company’s immediate owner, and/or if another entity separate from the named company with the SAM Registration owns or controls the business.
  • Include information (address, phone number, point of contact) about a company’s immediate owner.
  • Include information about the immediate owner’s CAGE Code, if there is one, and, if not, submit the paperwork necessary to get this immediate owner a CAGE Code – which, in many cases, also required us to submit an entire SAM Registration application on behalf of the immediate owner.
  • Include information about a company’s corporation status (e.g., domestic corporation, inverted domestic corporation, etc.)
  • Include information about the company’s unpaid federal tax liability, if applicable, and, if so, explain the basis of the assessment, how much has been paid, if a payment plan has been set up, and when the full amount will be repaid.
  • Include information about any felony criminal violations that the company has been convicted of, if applicable.
  • Include information about the company’s tax filing status, set-aside status (small disadvantaged, woman-owned, etc.), and if the company delivers any products that are listed on the federal List of Products Requiring Federal Contractor Certification as to Forced or Indentured Child Labor.

Also, we’ve been notified that at least one additional regulation change is coming in the fourth quarter of 2016, in this current iteration of SAM, which is Build 2016-06-24.

The GSA also made an estimated 500 changes to Schedules in place during 2016. These changes included merging schedules together and splitting schedules apart; adding or deleting products from one or more schedules; changing the status of schedules newly opened or closed in 2016; and bringing all GSA Multiple Award Schedules (MAS) in compliance with the Service Contract Labor Standards (SCLS). The GSA also now requires recent wage determination to be incorporated into task orders based on place of performance.

Some MAS Contract updates include:

  • Schedule contractors must comply with the most recent base rate posted, but responsibility is the Task-Order Contracting Officer (TCO)’s to obtain the applicable WD from gov or via the e98 process and incorporate it into the task order
  • Instead of abiding by a SCA matrix in the Solicitation, offerors submitting a new proposal or a contract renewal will be directed to SCLS index of applicable WDs at gov to verify that proposed base rates meet or exceed SCLS WD rates. Offerors must also check for additional regulations regarding non-professional labor categories in the Solicitation that applies to the schedule they’re proposing
  • Regardless of escalation method used, contractors cannot sell above negotiated Schedule pricing and must remain in compliance with SCLS WDs as included at the task order level
  • New wage determinations will not automatically merit a price increase and contractors may be required to provide their Contracting Officer with additional pricing justification
  • Additional changes to specific GSA pricelists by Schedule.

When these changes were finalized and put into effect, we went through each GSA Schedule a client has in place to ensure they were in compliance. In some cases, this meant requesting one or more price increases, or, occasionally, a price decrease. Contractors who did not comply with these changes could not make their products available via a GSA Schedule.

Other key changes this year affected IT Schedule 70, Schedule 738X, Schedule 75 (which reopened for the first time in several years), and to the GSA Professional Services Schedule.

The Defense Logistics Agency (DLA) also set a new requirement this year that makes maintaining a complete, accurate, and valid SAM Registration without letting it lapse more important than ever. Companies that let their SAM Registration lapse will no longer have a valid CAGE Code. CAGE Codes will now expire alongside a company’s SAM Registration. Not having a valid CAGE Code means a company WILL NOT be paid for completed work, even if the company is in the middle of providing services and/or products as the result of a contract award.

Clients also receive access to training materials, including templates that they can use when drafting correspondence, tracking opportunities, and debriefing with a federal buyer, and also to training videos.

For clients interested in grants, we’ve completed the full grants application, which includes the submission and verification of a full SAM Registration application. All of the regulation changes affecting companies with a current SAM Registration also affect companies who are registered to receive grants.

regulation-and-compliance

Each month we provide information about our clients, contact information, and product(s) and/or service(s) provided to our database of more than 23,000 federal buyers and procurement officers. Also each month, we distribute our client newsletter to each client. This newsletter includes a letter from our owner and president, Eric Knellinger, as well as key information about federal changes, important services we make available, and contract awards received by our clients.

US Federal Contractor Registration is the world’s largest and most trusted third-party government registration firm that as a Dun and Bradstreet Platinum Credibility Status. To further protect our clients, we carry $1 million in E&O and Professional Liability Insurance.

All SAM Registration changes for 2016:

  • Implemented the final Federal Awardee Performance and Integrity Information System (FAPIIS) Grants Guidance (2CFR Subtitle A, Chapter 1, Part 180, Chapter II, Part 200) to allow entities pursuing Federal assistance awards to properly report civil, criminal, and administrative proceedings during the SAM registration process. Updated Question 1 on the Proceedings page to display text specific to the entity’s selected Purpose of Registration. Updated the SAM User Guide to reflect the final FAPIIS Grants Guidance. Updated the SAM User Guide Content Glossary and the SAM Assistant to inform users the Government Business POC will be used by FAPIIS for communication purposes if no Past Performance POC is provided.
  • Implemented changes to the Reps & Certs section required by FAR Case 2016-001, Trade Agreements Thresholds to incorporate by reference the revised thresholds for application of the World Trade Organization Government Procurement Agreement and the Free Trade Agreements, as determined by the United States Trade Representative.
  • Increased the frequency of the SAM-Treasury Debt Management Service interface from weekly to twice a week shortening the amount of time needed to update entity registrations with delinquent federal debt subject to the Treasury Offset Program.
  • Updated the Register/Update Entity search fields and Registration Details display to only present those fields applicable to the user’s roles streamlining searches.
  • Updated the logic to determine if an entity is a small business concern in Representations & Certifications only if they meet the Small Business Administration (SBA) size standard as small for one or more North American Industry Classification System (NAICS) Code they selected reducing confusion and increasing data integrity.
  • Added the Subcommand Level 4 to the Federal Hierarchy better synchronizing hierarchy data received from the Federal Procurement Data System (FPDS) and increasing data quality for Department of Defense registered entities.
  • Added text definitions for SAM Assistant pop ups regarding the check box fields on the General Information page. Each business types list box is now distinguishable and with its own individual pop ups.
  • Implemented FAR Case 2013-020, Information on Corporate Contractor Performance and Integrity, to enable SAM to collect the required information on any parent, subsidiary, or successor entities with regard to offerors that are responding to a solicitation for a Federal contract.
  • Updated the application to display FAR Case 2015-011, Prohibition on Contracting with Corporations with Delinquent Taxes or a Felony Conviction improving regulatory compliance. This included adding two new FAR questions, adding FAR 52.209-11, and updating provision FAR 52.212-3.
  • Created a validation error for the email address field for the Create Individual Account on the User Information page increasing data quality.
  • Enhanced the data access request process to allow SAM users directly state whether or not they require SAM SFTP access for the Extracts.
  • Added a business rule to the entity management registration process that will only allow an entity to use their Social Security Number (SSN) as the TIN on the Business Information page if the entity identifies as a sole proprietor.
  • Updated the application to only display the Recertify link for users needing to recertify their SAM Data Access role when the user has 30 days or less before role expiration reducing confusion.
  • Updated SAM logo to navigate users directly back to the homepage from any unauthenticated page increasing usability.
  • Removed Skip to Content link, which served the same function as the Skip Navigation link, from the SAM.gov homepage. Users will be able to use the Skip Navigation link to navigate directly to the page content.
  • Fixed an issue where the user’s list of exclusions was not displaying if they canceled out of their exclusions during the Manage Exclusion process increasing usability.
  • Fixed an issue where the cross-reference type for records created via Search More Locations was not being set and fixed the validation logic for the cross-reference type field when updating an exclusion increasing data quality.
  • Updated the application to display “Please Select a Value” in the drop down list and a red asterisk when removing a cross-reference ensuring the decision to remove a cross-reference was a deliberate one.
  • Fixed an issue where deselecting entities from Search More Locations D&B tree did not remove them from the exclusion record increasing data quality.
  • Fixed a display issue where the correct Legal Business Name was not shown for certain Firm exclusions on the My Exclusions page under Manage Exclusions.
  • Changed the SAM Entity Management web service to default to the highest role available if there are multiple data access roles reducing user frustration.
  • Resolved an issue in SAM which prevented Chrome-browser users from downloading their Data Access Agreement Form when initiating a Data Access Request increasing audit quality.
  • Updated SAM to prevent users from creating multiple data access requests for the same data access role reducing user frustration and streamlining the Data Access Request process.
  • Updated the text that displays when a user is deleting a Work In Progress (WIP) entity registration record to clarify only the WIP record is being deleted reducing user confusion.
  • Fixed an issue where the Physical Address Line 2 was not displaying in an entity management registration providing more complete information onscreen.
  • Updated the CAGE Ownership Details sub-hand navigation link and page header to read Ownership Details increasing naming consistency.
  • Updated the application to display an asterisk for the State of Incorporation if USA is selected as the Country of Incorporation reducing user confusion.
  • Updated the small business size standards in accordance with the SBA Table of Size Standards effective February 26, 2016.
  • Added ALT text on all of the Reps & Certs FAR references presented to users for reference when completing the Reps & Certs section of an entity management registration clarifying the links open in a new tab.
  • Fixed the broken link on the Reps & Certs FAR Response 4 page Question 25 for FAR Provision 22.10003-4(d)(1) to provide accurate reference information to users.
  • Inserted SAM Assistant text for the drop downs, checkboxes, and text boxes within Reps and Certs increasing usability. A pop up now appears when a user enters the action field and provides the corresponding text definition.
  • Updated the language and VETS-4212 form number for the existing ‘read only’ FAR Provision 52.222-38, Compliance with Veteran’s Employment Reporting Requirements in accordance with FAR Case 2015-036.
  • Added validation rules to the POC Type field within the Optional POC section increasing data quality.
  • Fixed an issue where if a user has not selected any Optional POCs, the header was removed from the final Entity Review page reducing user confusion.
  • Updated the display of “Point of Contact” on the Entity Review, Entity Record and POCs pages to display “Points of Contact” for the header, Mandatory, and Optional POCs increasing usability.
  • Updated the application to display the country name instead of the country code on the View Invitation page when a user is viewing an invitation to join an entity increasing usability.
  • Updated the application to display “User Information” instead of “Personal Information” under Account Settings to more accurately reflect the type and purpose of information gathered.
  • Implemented validation logic for all POC fields during the System Account creation process increasing data quality.
  • Adjusted alignment when viewing additional detail (pressing the ‘+’) for an entity/exclusion on the Search Page enhancing the layout.
  • Updated the text in the Sort By drop down list on the Search Results page to display “Expiration Date” instead of “EXPIRATION_DATE” enhancing the layout.
  • Fixed an issue where running a saved search displayed different results from the same search ran in Advanced Search increasing usability.
  • Fixed an issue where the Quick Search filter for entity registrations by TIN was not returning results in certain circumstances increasing quality of search results returned.
  • Fixed an issue where an authenticated user searched using the main navigation bar Search field, , the Export Results file did not display the correct searched information and the PDF would not open increasing usability.
  • Fixed an issue where the Entity Record and Reps & Certs pages on the Entity Dashboard were not displaying the historical record functionality when viewing the registration via Register/Update Entity > Complete Registrations increasing usability.
  • Updated the frequency of the SAM-to-IRS TIN Consent interface from monthly to daily providing IRS with entities’ Consent to Disclose Taxpayer Information prior to conducting the required TIN Match.
  • Updated the links on the Exclusions Extract Data Package box to display links for all extracts produced within the past seven (7) days.
  • Updated the application to allow users to enter only specific characters within text fields increasing data quality for downstream systems by limiting unicode characters.
  • Identified and added page titles for any pages within SAM.gov that previously did not have distinct page titles to help identify the purpose of that individual page.
  • Updated the Status Tracker to display the correct status bubble for certain entity registrations which have passed IRS validation and are pending CAGE Code assignment increasing usability.
  • Fixed an issue where the daily interface to generate SAM extracts (INT050) was removing spaces from international ZIP Codes in the Extracts and Web Services increasing data quality for downstream systems.
  • Updated the error message for users who go to the SAM web service server using a web browser increasing usability.
  • Resolved an issue which prevented certain government users from downloading the BioPreferred Report in SAM increasing access to the previous fiscal year’s reported information.
  • Improved the usability of the POC Details page. Enhanced the Add Optional POC button and Copy From features for the Optional POCs section to allow registrants to select correctly formatted and completed POCs from the Copy From drop down menu increasing data quality.
  • Combined the Complete/Incomplete/Inactive Registration pages into one Existing Entity Registrations page streamlining the process and increasing usability. Registrants will be able to view and take action on all entities with which they have roles from one single page. Improved the Entity List to sort entities alphabetically and display the unique identifier (DUNS Number or DoDAAC) next to the Legal Business Name. Provided more information in the Registration Details returned to include the entity’s Purpose of Registration, CAGE Code, and Activation/Expiration Date.
  • Added application logic to display data entered on the Ownership Details page via the Entity Dashboard view, Search Dashboard view, and Entity Record PDF. Users will now be able to view their Ownership Details data as part of the complete entity record as well as within the context of FAR 52.204-17 Ownership of Offeror in the Reps & Certs section.
  • Improved the SAM Status Tracker user interface to make it consistent with the overall application. Updated it an HTML URL to a JavaServer Page (JSP). This not only improved the look and feel of the page, but also the security, by bringing it in the secured portal context within a portal session. Additionally, improved the on-page information provided on the registration process to reduce confusion.
  • Added validation logic for foreign ownership increasing data quality. On the General Information page, users who report a foreign Immediate or Highest-Level Owner on the Ownership Details page must select foreign-owned as one of the their business types. As well, if users indicate only U.S. owners on the Ownership Details page, they will not be able to select foreign-owned as an entity business type on the General Information page.
  • Improved usability for administrators to manage role requests. Added additional fields on the Manage Role Requests page. Redesigned the page layout to provide enough information for the administrator charged with reviewing and approving role assignments for their entity to take appropriate action at a glance.
  • Updated the Extract Daily/Monthly file links to incorporate Julian Dates reducing user confusion between files. Julian dates are a three-digit representation of the exact month and day of a given year.
  • Incorporated logic to allow users who register as a single-member Limited Liability Company classified as a disregarded entity to use their Social Security Number (SSN) as their Taxpayer Identification Number (TIN) in accordance with tax law.
  • Updated the data element label “POC Name:” on the Entity Overview Page to “Last Updated By:” as it only represents the user name of the entity administrator or representative who last updated the registration record. Official POCs are captured and presented in the POC section.
  • Changed the color of the Address Update Required “Yes” indicator triggered by the business monitoring service in the Entity Registration section from red to black removing the perception of an error.
  • Improved the exclusion management process by updating the Identification Information Address Display for Special Entity Designation Exclusions to match the display for Individual and Vessel Exclusions.
  • Improved small business concern validation logic to increase data quality. Certain types of entities can never be considered small for procurement purposes. Those types of entities can no longer select the Woman Owned Small Business (WOSB) or Economically Disadvantaged WOSB options as a socio-economic category on the on the General Information page. In addition, entities with a physical address outside the United States and its territories cannot be considered a small business concern.
  • Enhanced usability of key record date presentation. Reordered and renamed the key dates displayed within the Core Data module of an entity registration so users can more easily understand the Initial Registration, Submission, Activation, and Expiration dates.
  • Added validation logic to the SAM Exclusion uploader to verify the uniqueness of the National Provider Identifier (NPI) of a new or updated exclusion record improving data quality.
  • Triggered mandatory errors to be read aloud by a screen reader upon page reload increasing usability for users who navigate using only their keyboard.
  • Fixed the focus order on certain pages identified as not having a sequential flow from a screen reader perspective. The updated pages now mirror the flow from a sighted user’s perspective: left to right, top to bottom.
  • Updated all pages to include heading levels 1-5. Users relying on screen readers will encounter a consistent heading structure throughout the application increasing usability.
  • Removed the existing datepicker widget, which caused difficulty for keyboard navigation, from all affected pages. Implemented form input labels for date fields so keyboard-only users know the required format for the fields. Updated error messages on the Business Information and Proceedings Details pages to ensure users had all the necessary instructions to provide the appropriate data and continue with their registration.
  • Constrained focus within the page-level SAM Assistant component while it is activated to ensure keyboard-only users have a consistent user experience. All users must collapse the component before they can take action on the page.
  • Added labels to form input elements on the Login, My SAM, Search Records, and Search Results pages. Streamlined the Quick Search Results sub-filters to reduce confusion and ensure all input fields had appropriate labels increasing usability.
  • Fixed an issue where users were unable to delete certain alternate addresses on the Identification Information page for SED/Vessel Exclusions improving data quality.
  • Removed the “Upload” button from the “Cancel Exclusion Update” page reducing user confusion.
  • Fixed an issue where the list of My Exclusions would not display on page load after canceling out of the Delete or Deactivate process while managing exclusion records improving usability.
  • Removed the limitation on the number of alternative addresses per exclusion in the SAM Exclusion uploader improving data quality.
  • Fixed an issue where users could submit a registration update, if all mandatory information was complete, after only passing the TIN Consent page. Users must review each page in their registration to certify their information is current and accurate.
  • Fixed a typo in the Federal Service Desk phone number included in the email sent when a user deactivates their entity management registration.
  • Fixed an issue where a screen reader was not reading the pop-up message after the Start Registration button on the Overview page was activated. This pop-up is a quick reminder to the user of what information is needed to get started with their registration.
  • Improved the final Entity Review page in the Core Data section by removing the duplicate Physical Address and adding the Missing Address Line 2 increasing usability.
  • Updated hyperlinks on the Commercial and Government Entity (CAGE) Code, Ownership Details, and Predecessor Details pages to navigate users to the correct CAGE Program or NATO Support and Procurement Agency (NSPA) sites providing quick access to external resources.
  • Recorded new and updated SAM Assistant text for Predecessor Details and other Entity Registrations pages to provide on-screen help for users registering in SAM.
  • Added logic to only allow government entities to select NAICS from Sector 92-Public Administration increasing data quality.
  • Fixed an issue where business type 52 (Self Certified Small Disadvantaged Business) was not being removed from the entity management registration when the user selected No to Question 17 in Reps & Certs increasing data quality.
  • Updated the FAR links on the Reps & Certs page so users are navigated to the correct provision providing quick access to external resources.
  • Removed any links or references to the now-reserved DFARS provision 252.225-7022 from the SAM Reps & Certs section reducing potential confusion.
  • Revised the title of the expanded NAICS table under the View More button in FAR 52.212-3 paragraph (c) and FAR 52.219-1 paragraph (c) to clearly state it represents Small Business Status by NAICS Code reducing potential confusion.
  • Fixed an issue where a previously selected country continued to display under DFARS 252.216-7008 even after the user changes the answer to Question 35 to No improving data quality.
  • Updated the small business concern logic so foreign-owned entities with a physical address in the United States and its territories are not prevented from being considered small for procurement purposes improving data quality.
  • Updated FAR 52.204-20 Predecessor of Offeror in SAM Reps & Certs to match the language of the provision effective April 2016.
  • Removed the Sole Proprietor POC type from the entity registration if the user changed their Entity Type from Sole Proprietor to a different selection improving data quality.
  • Fixed an issue where the Address Line 2 field of the POC page was not displaying in the application improving data quality.
  • Fixed an issue in the managing of entity users where the “Back to Users List” button was not navigating the user back to the User List page, with the radio buttons and search terms still displayed.
  • Removed the 200 record limit on the Manage Roles page so all entities with which a user has roles will display in the Entity List. Updated the display of the federal and non-federal hierarchy for entity administrator and help desk users.
  • Removed the 200 record limit from the Manage Roles > Summary page so it displays all of the Parent and Children entities that the user is being given roles to or being removed from.
  • Removed the “Unlock Button” on the Request Role page for users who do not have their account locked reducing confusion.
  • Removed the white space from the bottom of the Request Roles with New Entity > Select Entity page for a federal user improving the layout.
  • Fixed an issue where, the Roles header on the Summary page was formatted incorrectly when a user requested a role with an entity reducing confusion.
  • Fixed a typo on the Invitation Sent > Confirmation page from “Invitation Set” to “Invitation Sent” reducing confusion.
  • Left aligned the fields on the Invite User > Summary page improving the layout.
  • On the Invite User > Summary page, removed the fields that are not required to be populated which includes the Department and Agency Code fields, Level Status, and Address Line 3 and 4 reducing confusion.
  • Fixed an issue where users could not remove the second POC during the System Account creation process.
  • Updated the sub-navigation so users have clear instructions and navigation options for managing their user profiles improving the user experience.
  • Created a reminder to re-enter password data in the Password and Confirm Password field for users who receive error messages during the Individual Account creation process ensuring users have the information they need to continue creating their user account.
  • Fixed an issue where running a search in Advanced Search-Entity and running a saved search with the same criteria returned different results improving usability and search reliability.
  • Added the Content and Search Glossary sections of SAM to the page focus order. Users can tab to the glossary section and expand/collapse the section using keyboard action only improving accessibility.
  • Fixed the issue where a middle name shifted down one record in Advanced Search – Exclusions results. The middle name corresponding to an individual’s name is now correct when saved as a PDF improving search result data quality.
  • Updated the error message that displays when a user enters a search term into more than one box within Quick Search reducing confusion.
  • Updated the static error message when searching for an entity via search and the entity dashboard reducing confusion.
  • Incorporated a usability recommendation to tie the Reports section to user roles. Unauthenticated users and non-federal users without roles to the searched entity will no longer see a Reports section displayed. Federal users and users with roles for the entity will continue to have access to the Service Contract Report (SCR) and BioPreferred Report sections.
  • Added section P (Ownership of Offeror) and R (Predecessor Details) to FAR provision 52.212-3 for the SAM API increasing completeness of responses returned.
  • Updated the SAM Entity Management web service to remove an existing undefined namespace improving downstream data processing.
  • Resolved an issue that prevented the Entity Management web service response from properly sequencing Entity records which shared a common 9-digit DUNS in order of the DUNS+4 value improving downstream data processing.
  • Added the Service Contract Report box and link to the System Account Entity Management extract page improving data access.
  • Updated FAR 52.212-3 to include sections P (Ownership of Offeror) and R (Predecessor Details) in the Web Service improving completeness of responses returned.
  • Resolved an issue in the Exclusion Search web service which prevented searches by name when other parameters were present and null improving completeness of responses returned.
  • Updated the <includeArchive> tag in the SAM Exclusion Search web service to be <includeInactive>, removed it from the doSsnSearch operation, and made the tag searchable in the doSearch operation, improving consistency.
  • Removed the Sensitive extract links from displaying for users with only For Official Use Only (FOUO) access. Although the links wouldn’t work because the user didn’t have the right data access role, their presence caused confusion.
  • Fixed an issue where the exclusion search web service contained undefined namespaces which was preventing response parsing improving downstream data processing.
  • Posted a simplified SAM Exclusions Public Extract layout document to increase user understanding of the data provided.
  • Updated the Google Geolocation/Sunlight API logic to use ZIP Code as secondary parameter if the Google Geolocation does not return a result, increasing Congressional District data completeness.
  • Updated additional text and user-guide references of “Foreign Owned and Located” text to correctly read “Foreign Owned” in compliance with the data element definition change implemented in February 2016.
  • Updated the HMTL markup throughout the SAM application to better conform to the W3C HTML specifications. Examples include using appropriate tags to impart semantic meaning, updating tags used for presentation purposes only, and including only one pair of html open/close tags per page.
  • Added unique page titles to the additional SAM login page scenarios. Updated the Page Description sections and page markup to provide clear instructional text and consistent heading level structure.
  • Updated the SAM logo to navigate a user back to the homepage when selected.
  • Updated the Small Business Administration (SBA) text and links text on the General Information > News > Announcements page and the My SAM page to provide more useful information to small business concerns.
  • Constrained the emulation mode for SAM on Internet Explorer from version 8 to version 9. This will allow optimal performance for SAM users using IE9 and above moving forward.
  • Removed redundant login fields and links in the global banner to improve user experience for users relying on screen readers.
  • Improved the My SAM page sub-navigation menu to enable users navigating via keyboard only to expand and collapse the menu sections increasing accessibility