Per a Department of Defense memo dated 8.21.12, a Class Deviation has been granted exempting contractors and contracting officers from specific CCR and ORCA [now SAM] requirements until further notice and resolution of SAM performance issues. Click here to read the full DoD memo which provides guidance on when CCR (SAM) registration is not required, when CCR (SAM) registration will not be checked, and when an expired ORCA (SAM) record will be acceptable. Also of note, GSA has reestablished the EPLS website (www.epls.gov) to provide contracting officers the ability to ensure a prospective contractor is not actively excluded from procurement actions.
If you have tried to update your company’s CCR or ORCA information lately, you’re probably ready to pull your hair out. The problem is SAM (System for Award Management) is all hosed up. SAM intended to consolidate eight acquisition databases, including the Central Contractor Registration (CCR), the Online Representations & Certifications Application (ORCA), the Past Performance Information Retrieval System (PPIRS) and five others launched July 30th, then went offline for maintenance until August 6th. SAM went back up Aug. 7, but with continued slow performance and other issues.
Prodded by complaints from the Chief Acquisition Officer’s Council, on August 7th GSA issued IBM an official Notice of Concern telling the company to develop a plan of action and milestones for how they will make SAM work more smoothly
- and to fix the system or risk penalties. GSA’s Notice to IBM stated, “IBM has not delivered a stable and fully functioning initial operating capability (IOC) for SAM Phase 1… GSA instructs IBM to provide a list of all issues and defects in SAM from go-live to date with a current status of the issue and defect. Further, IBM is instructed to respond with a Corrective Action Plan (CAP) no later than close of business, August 13, 2012.” A letter of concern is a step before a ‘cure letter’.
IBM has been working on the project since 2010 under an eight-year, $74 million contract. Sources told FederalNewsRadio, IBM was taking steps to address SAM’s problems. These included adding more servers and bringing in a new team of employees.
In the meantime, in our 8/2/12 SAM post Aronson provided SAM’s basic information for creating a username and password if previously registered in CCR, FedReg,ORCA, or EPLS. We’ve continued to review the 350 page SAM Phase 1 User Guide and despite its bulk, answers and definitions are missing and explanations are unclear. Until the Corrective Action Plan is implemented you may wish to save a tree!
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