The President’s Executive Order – Restoring Common Sense to Federal Procurement involves a comprehensive overhaul of the Federal Acquisition Regulation (FAR) and subsequently the FAR Supplements. As the FAR is being updated it includes changes to contract provisions and clauses. The System for Award Management (SAM.gov), the official U.S. government website where entities register to do business with the federal government is also being streamlined.
What Impact Does the FAR Overhaul Have on the SAM.gov?
A big impact, hopefully making it more efficient. Currently, contractors complete three types of representations and certifications in SAM.gov during an initial registration or annual update. These include representations and certifications specific to the:
- Entity
- Procurement
- Submission of an offer
While SAM.gov is under review, the intent is to continue to include entity-level representations and certifications in SAM.gov and remove the procurement specific and submission of offer representations and certifications. Since solicitations contain the most current versions of the provision, there is no need to include the duplicative representations and certification in SAM.gov. This supports the FAR overhaul initiative of reducing duplication and increasing efficiency.
When Will the Changes in SAM.gov be Made?
The FAR Council is required to complete the FAR update by early October 2025 and is estimating the changes to SAM.gov to occur around January 2026. Contractors will still be required to annually update their SAM registration even though the representations and certification in SAM.gov may not align with the updated FAR provisions in the solicitations. Contracting Officers may include language in the solicitation indicating there is a disconnect between SAM.gov and the solicitation and they will be relying on the provisions in the solicitation.
What About my Current Representation and Certification Form for my Subcontractors
Standard forms will need to be reviewed and updated to ensure the subcontractor is certifying to the appropriate provisions. However, as was discussed in our article, “Are Representations (Reps) and Certifications (Certs) Required of Subcontractors?,” higher-tier contractors have a limited requirement to get representations and certifications from their subcontractors.
Takeaways
Streamlining SAM.gov to remove the two sections of the representations and certifications will reduce the annual SAM registration and update process. Until SAM.gov is updated, contractors will continue to update their registration completing the representations and certifications even though they may not align with the current changes to the FAR.
It is important for contractors to review each solicitation for any new provisions. Even though their SAM registration is current, you may be asked to sign additional representations and certification because of changes to the FAR provisions.
Contractors that use a standard Representation and Certification Form will need to review and update the form as many of the provisions have been incorporated into an existing clause, deleted, or renumbered. Relying on a copy of the SAM.gov representation in the procurement file to support the contractor’s certifications will no longer suffice. Remember not everything a prime has to do flows down to the subcontractors.
Support for SAM.gov Registration and Compliance
Redstone GCI assists government contractors with understanding government requirements and completing System for Award Management registration and updates. Our team provides guidance on maintaining compliance with FAR and agency-specific provisions, reviewing representations and certifications, and addressing updates that may impact solicitations or subcontractor requirements. We also support clients with related services such as compliance consulting, outsourced accounting, contracts administration, and training, helping government contractors strengthen internal processes and reduce risk while navigating the evolving regulatory landscape.
Lynne is a Director with Redstone Government Consulting, Inc. providing government contract consulting services to our clients primarily related to Commercial Item Determinations and support, Cost Accounting Standards, DFARS Business System Audits, Proposals, and Incurred Cost. Prior to joining Redstone Government Consulting, Lynne served in several capacities with DCAA and DCMA for over 35 years. Professional Experience Lynne began her career working with DCAA in the Honeywell Resident Office, Clearwater, FL in 1984. Lynne’s experience included various positions which involved conducting or reviewing forward proposals or rate audits, financial capability audits, progress payments, accounting and estimating systems, cost accounting standards, claims and disclosure statement reviews. She is an expert in FAR, DFARS, CAS and testified as an expert witness. Lynne assisted in drafting the commercial item guidance for DCAA Headquarters. Lynne was assigned as a Regional Technical Specialist where she provided guidance to 20 field offices on highly complex or technical issues relative to forward pricing, financial capability or progress payment issues. As an Assistant for Quality, she was involved in reviewing and ensuring audit reports were in compliance with policy and GAGAS as well as made NASBA certified presentations to the staff including but not limited to billing reviews, CAS, unallowable cost and progress payments. To enhance her experience in government contracting, Lynne accepted a position with DCMA in 2015 as part of the newly organized DCMA Cadre of Experts in the Commercial Item Group. This included performing reviews of prime contractor’s assertions and/or commercial item determinations as well as performing price analyses. Lynne was a project lead and later became a lead analyst where she engaged with the buying commands on requests and reviewed price analysis reviews performed by a team of 5 analysts. She also assisted the DCMA CPSR team relative to commercial items and co-instructed the Commercial Item Training presented to DCMA. Education Lynne earned a Bachelor of Science Degree in Accounting from the University of Central Florida. Certifications State of Florida Certified Public Accountant State of Alabama Certified Public Accountant Defense Acquisition Workforce Improvement Act (DAWIA) Level III- Auditing DAWIA Level III – Contracting