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Department of Defense Waiving SAM registration requirements for emergency response vendors

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Due to the emergency situation caused by the hurricanes, contracting offices are using authority to waive the requirement for SAM registration in purchases that directly support the emergency response.  If you’re helping a vendor who is not yet registered in SAM but needs a CAGE code, the expedited process instructions are below. 

(information on selling to disaster response agencies)

Subject: Obtaining CAGE codes for vendors responding to the Hurricanes

Hello everyone – obviously we expect that there will be many offices responding to the hurricanes with emergency purchases where SAM registration is waived per FAR 4.1102(a)(3)(iii) and part 18.102.  We want to get the below instructions out for how you can still help your vendors obtain CAGE codes (if they don’t already have one) that are required per FAR 4.1804 for other than micro-purchase actions:

1 – Go to https://cage.dla.mil

2 – Choose ‘Request or Update a CAGE Code’ and hit Begin on the next page

The user will then be taken through a series of pages where they provide the data necessary to set up a CAGE code, but before they get to those elements, they have to answer a few more questions.  In order for the CAGE website not to just direct them to go register in SAM, the users need to answer exactly as follows:

  1. Question – Do you have a registration for this same entity in process at System for Award Management (SAM)?  Answer – No
  2. Question – Do you plan to receive contract payments or grants from the U.S. Government?  Answer – No
  3. Question – Are you a NON-U.S. entity (government or commercial)?  Answer  No (note – if the entity really is foreign, answer Yes, but realize that the user will be directed to contact his/her home country codification bureau)
  4. Question – Are you requesting a new CAGE Code?  Answer – Yes
  5. Question – Do you have a previous business?  Answer – No
  6. Question – Please choose your Entity Type   Answer either – (1) U.S Commercial Company/Firm, Organization or Government Entity (non-federal) OR (2) Sole Proprietor Business
  7. Question – Please choose a Primary Purpose for this CAGE   Answer -Other
  8. Question – Please describe the primary purpose for this CAGE  Answer – Provide Urgent Hurricane Irma Support (or Harvey or Jose as appropriate)

From here on, the user is just providing their name, address, etc.information.  Should be simple from here.

Be aware – when a user requests a CAGE code be established via this method (instead of through registering in SAM), it goes into manual processing at DLA in Battle Creek.  It’s very important that the user enter ‘hurricane’ in the purpose field after they choose other.  The CAGE team is going to search for that term in each request that comes in and move those to the top to be worked.

For non-GPC actions, it’s important that the vendor get a CAGE code assigned and it be included in the contract when its distributed to ensure that their eventual payment is streamlined and not held up for manual action.  Note also that without a valid CAGE code, an action will fail Procurement Data Standard (PDS) validations.

If these are going to be on-going contracts (such as reconstruction), it would behoove the vendors to eventually actually get registered in SAM (they can use the CAGE code that will be assigned in this process when they do so) even if they’re not technically required to do so because the contract was initially exempted due to the emergency.  Being registered in SAM will just make the whole invoicing and payment processes run a bit smoother if the contract lasts for a while.

Lisa Romney, Defense Procurement and Acquisition Policy Office of Acquisition Technology and Logistics

 

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Before You Start… (and how to make the best use of your PTAP)

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Virginia PTAP (and our nationwide colleagues) are happy to welcome you to government contracting. We will do our best to help you succeed at selling to state, local, and federal agencies.

Some businesses, however, aren’t ready for government contracting, and your meeting with a PTAP counselor, or your attendance at a class can be frustrating, overwhelming, and (let’s be honest), disappointing.

So let’s get this secret out of the bag: PTAP is not intended to help you start a business. That’s outside our mission, that’s something our grant funder (Department of Defense) specifically frowns upon, and that’s the kind of assistance we recommend you seek from our resource partners, such as the Small Business Development Centers, Women’s Business Centers, Veterans Business Outreach Centers, and SCORE.

In fact, before you meet with a PTAP counselor or attend even our introductory “Basic Training” class, we recommend that your company obtains:

Legal Requirements (for any business)

  1. State entity registration if your business is anything other than a sole proprietorship (LLC, Corp, LLP….)
  2. Federal Tax ID Number (TIN / EIN) from the IRS
  3. Business license from your state / locality (in Virginia, it’s called a BPOL)
  4. Business Plan

PTAP Counselors won’t usually ask to look at your documentation, unless they’re helping you submit a certification that requires above-mentioned paperwork.  However, in order to start registering as a vendor to any government entity, businesses must meet certain basic requirements.  If you are sure that you are going to pursue government work, get these out of the way.  And as far as the Business Plan – again, while we don’t require written proof that you created one for your business, we do want to ascertain that you are serious, that you have considered the pros and cons and financials and business structure and have a plan.  We will absolutely help you refine it, give you a reality check, and assist with a proof of concept; but if you’re not serious about your business, there really isn’t much we can do to overcome that.

Government Contracting Specific Pre-Requisites

  1. Identify your NAICS and PSC Codes (Federal)
  2. Identify your NIGP Codes (State / local)
  3. Obtain a DUNS Number
  4. Register in SAM = obtain a CAGE Code.

This is a bit more of a chicken-and-egg category.  Yes, we can help you figure out all of these codes and numbers and what you should select.  However, the best advice at the outset is that you try to identify the codes that apply to your business. Attempt to get a DUNS number. See if you can register in SAM.  If you get those steps out of the way without a snag, then your meeting with your counselor can cover more in-depth, “next step” material.  And if you do have questions or run into technical difficulties, that’s absolutely an area where a counselor’s perspective will be invaluable.  (Hint: make sure the physical address for your Tax ID, DUNS, and SAM is *identical* down to the letter and abbreviation).

You and your counselor should review your registrations during your session, and we will have some insight into additional / related / adjacent codes to consider.  You’ll hear tips and tricks in classes.  We’ll explain the purpose and utilization of all of these by your target customers. And we’ll give you next steps, like competitive and customer analysis, DSBS profile creation (and much more!) — built on the foundation of the basics you have completed.  There’s a lot more to government contracting, so the sooner we get these “pre-requisites” out of the way, the sooner we can do some real work.

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