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Check Your SAM Registration Early and Often

What You Need to Know

  • Key takeaway #1

    Register and renew/update early. Although we generally are seeing smoother registration processing recently, issues and delays remain. We advise clients to begin new registrations—and updates and renewals to existing registrations—as early as possible to get ahead of potential delays (e.g., with entity validation).

  • Key takeaway #2

    When in doubt, reach out. Our team is experienced in navigating SAM registration issues and can provide support at every juncture. Please do not hesitate to reach out.

Client Alert | 1 min read | 05.25.23

Federal contractors must be registered on SAM.gov to be eligible for award of federal contracts.  Failure to do so can have significant consequences, as the recent U.S. Court of Federal Claims (CFC) decision in Myriddian, LLC v. United States, No. 23-443 makes clear. 

In Myriddian, the Centers for Medicare & Medicaid Services (CMS) awarded a five-year, $11 million contract to Cloud Harbor Economics, LLC (Cloud) for coding support services.  Myriddian, an unsuccessful offeror, protested at the CFC, arguing Cloud was ineligible for award under FAR 52.204-7, which provides that an offeror must “be registered in SAM when submitting an offer or quotation, and shall continue to be registered until time of award.”  Although Cloud was registered in SAM at the time of proposal submission and at the time of contract award, Cloud’s registration had lapsed for three weeks during the proposal evaluation period.  The CFC sustained the protest, holding that FAR 52.204-7 unambiguously requires a contractor to maintain its SAM registration throughout the entire proposal and evaluation process, and that an agency lacks the authority to waive that requirement.  Because Cloud failed to “continue to be registered until time of award,” the CFC found Cloud ineligible for award and enjoined CMS from proceeding with the contract.  

Myriddian comes on the heels of the CFC’s recent decision in Thalle/Nicholson Joint Venture v. United States, No. 22-755, upholding an agency’s elimination of a joint venture from competition where each of the joint venture members was individually registered in SAM at the time of proposal submission, but the joint venture itself was not.  These cases stand as cautionary tales reminding offerors to ensure active SAM registration at all times throughout the proposal process and not to wait until the last minute—especially given processing delays that contractors continue to experience with SAM registrations.

Insights

Client Alert | 7 min read | 10.27.26

New Developments in DOJ Whistleblower Policies and HHS Disclosures: Key Takeaways for General Counsel, Chief Compliance Officers, and Boards

On October 20, 2026, the U.S. Department of Justice’s (DOJ) National Fraud Enforcement Division announced a new whistleblower rewards initiative, the Fraud Whistleblower Incentive Program (WHIP). Assistant Attorney General Colin M. McDonald issued a directive earlier this month directing Division leadership to design and implement policies and programs that incentivize whistleblowers to bring forward credible information pertaining to fraud. The new WHIP incentive pays awards of $10,000 to $30,000 for qualifying tips at or around the time criminal charges are filed or unsealed, rather than years later at case resolution....