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  • Question

    Are subcontractors required to have an active CAGE and SAM registration? FAR 9.402 and 9.405 indicate that agencies shall consent to subcontracts only with responsible contractors, and SAM is one of the mechanisms used to keep track of vendor responsibility.


    Answer

    FAR 4.1102(a) provides the policy regarding the registration in SAM, and DFARS 204.1103 and DFARS PGI 204.1103 provide the procedures for DoD. Provision 52.204-7 provides the requirements to offerors as to what is required for SAM. The bottom line with all of these references is that subcontractors do not require an active CAGE and SAM registration. To better understand SAM, check out the below link. 

    https://www.federalregister.gov/documents/2018/09/26/2018-20706/federal-acquisition-regulation-system-for-award-management-registration

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