In 2012, the Federal Government
released SAM.gov in an effort to consolidate CCR/FedReg, ORCA, and EPLS. The
System for Award Management, better known as SAM, provides access for all types
of companies to create business records that describe their business types,
service and products offerings, and allows the Federal Government to engage and
do business with these corporations in a more streamlined manner.
Recently, JHC Technology, Inc.
submitted an RFP to a Federal Government Agency. As we hope all contracting
officers do their due diligence, the reviewing contracting officer from the
agency contacted us to verify our small business status. Having previously
successfully registered our small business with SAM and being a SDVOSB verified
by the Department of Veterans Affairs, we all looked at each other with a
raised eyebrow and asked the same question – why can’t the contracting officer
just look up our small business status on SAM.gov and figure out that we really
are a small business? It turns out that the answer is not clearly evident on
any company’s profile in SAM. It actually requires the contracting officer, and
anyone else looking for this information, to dig a bit deeper into the site to
find out.
SAM does not actually post the small
business concern in the general information tab of a company’s profile because
the small business classification depends on the North American Industrial
Classification (NAICS) code the business utilizes. In SAM, each NAICS code has
a revenue cap assigned that determines whether a company is considered a small
business under that code. So while you may consider yourself a small business
under the SBA general standard, SAM has a different classification in mind.
So, how do you find an entity’s small
business status?
2.
Search for the entity under
“Search Records”
3.
In the next screen, enter either
the company name, the DUNS Number or CAGE Code for the business you are trying
to find.
4.
On the search results page,
click on “View Details” for the entity you need to view
5.
In the left menu bar, click on
“Reps & Certs”
6.
Scroll down to 52.212-3 or
52.219-1 and click on the provision. In some browser versions, this does not
appear to be a hyper link. Scroll your mouse over the provision and click on it
anyway and this will expand the record.
7.
Scroll down to view the NAICS
table, where you will see listed the company’s NAICS code, name of the code, any exemptions, the
revenue size standard that sets the cap for small business, and whether the
company is a small business under that particular NAICS code.
Additionally, written under the table in section
(1) and (2), you will be able to see if the business is a small business as a
whole as well as whether the business is a veteran owned small business. Below
is a sample of the NAICS chart you will see:
According to SAM, contracting officers
are required to check the certifications created by each business when
considering a contract award. While it may be understandable for many reasons
why each contracting officer needs to complete this verification, it begs the
question of whether the Federal Government has educated and trained the
contracting officers on the use of their brand new site. Luckily, our contracting
officer contacted us to inquire about our small business status, however, I
think we would have all been very disappointed if we lost this bid based on the
unclear nature of the SAM site.