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SAM Error? You’re Out—Court of Federal Claims Slams the Door on Proposal Slipups

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In Analysis, Studies, and Training International, LLC, et al. v. United States, U.S. Court of Federal Claims, Nos. 24-1720 & 25-76 (Consolidated) (April 14, 2025)​, two offerors were excluded from an Air Force procurement for drone training support after failing to meet SAM.gov requirements tied to women-owned small business (WOSB) certification and registration continuity. Both Analysis, Studies, and Training International, LLC (ASTI) and SOFIS-TRG, LLC (SOFIS) protested, arguing that the SAM-related issues were clerical or cured, but the Court upheld the agency’s decision, underscoring the strict enforcement of SAM compliance in federal contracting.

The Decision
The COFC denied the protests, ruling that:

  1. ASTI Excluded for Failing to Submit SAM Certifications: Although ASTI had a SAM profile, it did not submit its SAM certifications with its proposal, and its profile at the time did not reflect WOSB status. The Court found the failure to submit certifications to be a material error warranting exclusion from the competition​.
  2. SOFIS Excluded for SAM Registration Lapse: SOFIS submitted its SAM certifications with its proposal, but its registration lapsed for five days during the evaluation period. Under the version of FAR 52.204-7(b)(1) in effect at the time, contractors were required to be continuously registered in SAM from submission to award. The Court found the lapse disqualified SOFIS, even though it was later cured​​​​.
  3. Recent FAR Amendment Did Not Apply Retroactively: SOFIS argued that a November 2024 amendment to FAR 52.204-7, which removed the continuous registration requirement, should apply retroactively. The Court rejected this, holding that FAR changes apply prospectively unless stated otherwise, and the amendment didn’t meet that standard​.
  4. Clarification Not Required for Material Errors: ASTI also argued that the agency should have allowed it to clarify its missing certification. The Court disagreed, finding that the omission was not a minor issue, but a failure to meet a material solicitation requirement​.

Key Takeaways for Contractors

  1. If Required by the RFP, SAM Certifications Must Be Submitted with the Proposal: If the solicitation requires it, especially in small business set-asides, offerors must include printouts of SAM.gov certifications confirming eligibility. “We’re registered” isn’t enough.
  2. Check Your Status, and Don’t Assume SAM Is Up to Date: Both companies failed to verify that SAM reflected the correct small business designation (in ASTI’s case) or had active status at all times (in SOFIS’s case). These oversights proved fatal.
  3. Lapsed Registrations = Ineligible, Even If Brief: Before the FAR was amended, any lapse in SAM registration, even for just a few days, rendered an offeror ineligible. This decision reaffirms that this rule applies strictly and without agency discretion.
  4. New FAR Rule Does Not Fix Old Mistakes: The 2024 amendment to FAR 52.204-7 only applies prospectively. If your solicitation predates November 12, 2024, the old rule still governs.
  5. No Second Chances for Material Requirements: The Court emphasized that agencies are not required to allow clarification of omissions when the failure involves a material solicitation requirement (like submitting proof of WOSB status).