A recent Government Accountability Office (GAO) bid protest decision in TLS Joint Venture, LLC reminds companies competing for federal government contracts that rules are rules, and you must have an active System for Award Management (SAM) registration to be eligible for an award. Here, second-in-line offeror and protester, TLS Joint Venture, LLC (TLS), argued the Navy unreasonably awarded a custodial services contract to Silas Frazier Realty, LLC (SFR) because SFR’s SAM registration lapsed during the agency’s proposal evaluation period. The record showed SFR’s SAM registration expired on December 11, 2023. Although SFR submitted its SAM renewal three days before, on December 8, the General Services Agency (GSA) did not activate the renewed registration until December 12, one day after SFR was awarded the contract. In deciding TLS’s protest, GAO concluded that SFR’s SAM registration had, in fact, lapsed—albeit for a day—since the renewed registration was not processed and activated by GSA until December 12. GAO sustained the protest and directed the Navy to terminate the contract awarded to SFR, positioning the protester, TLS, as the next-in-line offeror, for the new contract award. 

POV: Companies competing for federal government contracts must be intentional about keeping their SAM registrations both active and accurate at all times, particularly when submitted bids and proposals are under consideration for award. An expired SAM registration gives competitors—as well as the government—an easy way to keep a contract out of your hands. Don’t snooze on SAM.