After securing a federal contract, contractors must maintain an active SAM registration with annual renewal and immediate updates for any entity changes. Post-award management requires establishing financial processes for performance-based or progress payments, which typically operate on 30+ day cycles. Contractors must track performance metrics as evaluations in CPARS directly impact future award opportunities. Proper documentation and compliance with federal regulations are essential for payment processing and audit readiness. The following sections explore critical post-award responsibilities in greater detail.
SAM Registration Maintenance: The Foundation of Federal Contract Compliance
The cornerstone of successful federal contracting lies in maintaining an active System for Award Management (SAM) registration. Federal contractors must renew their SAM profiles annually, with the 365-day cycle beginning from their last certification date.
Maintaining active SAM registration forms the essential foundation for federal contracting success, requiring annual renewal to preserve eligibility.
Registration accuracy remains paramount throughout the contract lifecycle, as all payment processing and award compliance depend on current SAM status. According to federal requirements, compliance with 2 CFR Part 25 is essential for maintaining valid entity identifiers and active SAM registrations. Organizations seeking federal funding opportunities must adhere to these requirements to remain eligible for contracts and grants.
Effective renewal strategies include implementing a dual-month approach, where contractors submit renewals two months before expiration to accommodate the recommended 10-day processing buffer. This proactive timeline management prevents the severe consequences of expiration, which immediately triggers ineligibility for both new awards and payments on existing contracts.
Contractors should regularly verify their SAM status through the SAM.gov portal, as expired registrations halt all contracting activities without grace periods.
The system requires immediate updates whenever entity details change, particularly for legal business name modifications and ownership transfers.
Navigating Financial Management Milestones in Your Government Award
Once a federal contract award occurs, contractors must immediately establish robust financial management processes to guarantee compliance with Federal Acquisition Regulation (FAR) requirements.
Proper financial forecasting becomes essential as contractors navigate between performance-based payments and traditional progress payments.
Contractors should note that performance-based payment schedules cannot exceed 90% of the contract price and must be explicitly defined in dollar values or percentages. These schedules require modification when contract actions greatly affect pricing milestones.
Meanwhile, progress payments based on costs follow standard rates with ordinary or alternate liquidation methods.
To mitigate payment risks, contractors should:
- Maintain cash reserves to buffer 30+ day payment cycles
- Align subcontractor terms with government payment schedules
- Implement specialized compliance training for finance teams
- Secure backup financing options for potential disbursement delays
Government contracts require meticulous attention to payment documentation and audit readiness to prevent suspension of payments due to accounting deficiencies.
Unlike FAR performance-based payments, Other Transaction milestone payments provide greater flexibility and can serve as effective management tools throughout project execution.
Maintaining accurate records in the SAM database is crucial for successful post-award compliance audits and continued eligibility for government contracting opportunities.
IDIQ contracts provide revenue stability but often create cash flow challenges due to unpredictable task order timing and delayed payments.
Performance Tracking and Reporting Requirements for Federal Contractors
Successful federal contractors understand that performance tracking represents a critical component of post-award contract management, governed primarily by Federal Acquisition Regulation (FAR) Part 42.15. These regulations establish a framework for collecting and documenting contractor performance information through standardized evaluations.
Performance evaluations are mandatory for contracts exceeding the simplified acquisition threshold, with specific exceptions for certain construction and architect-engineer services.
Federal contracts above simplified acquisition thresholds require performance evaluations, with limited exceptions for specialized construction services.
The Contract Performance Assessment Reporting System (CPARS) serves as the primary tool for documenting these assessments, which evaluate contractors across multiple criteria:
- Technical quality of deliverables
- Cost control capabilities
- Schedule adherence
- Management and business relations
- Regulatory compliance
Contractor responsibilities include maintaining accurate information in the System for Award Management (SAM) and responding to evaluations appropriately. Contractors are specifically responsible for ensuring the accuracy and currency of their SAM data during the entire contract performance period.
These performance records greatly impact future contract award decisions, making diligent attention to evaluation processes essential for maintaining competitive positioning in federal contracting. The streamlined processes offered by SAM registration enable businesses to efficiently navigate post-award requirements while maintaining compliance with federal regulations.
Frequently Asked Questions
How Do I Transfer a Federal Contract to Another Business Entity?
A contract transfer to another business entity requires executing a novation agreement under FAR 42.1204. The process involves:
- Identifying the responsible contracting officer
- Submitting a complete novation package with asset transfer documentation
- Providing buyer’s financial statements and organizational documents
- Demonstrating the buyer’s capability to perform the contract
Government approval is mandatory, as unauthorized transfers violate the Anti-Assignment Act.
Once approved, the original contractor is relieved of obligation and the successor assumes contract responsibilities.
Can SAM Registration Be Expedited During Contractor Emergencies?
SAM registration cannot be officially expedited during contractor emergencies through standard channels.
However, federal agencies can utilize emergency acquisition flexibilities under FAR Part 18 to bypass typical registration requirements in urgent situations.
While emergency registration remains subject to standard processing timeframes, agencies may allow contractors to begin work before completing full SAM registration when unusual and compelling urgency exists.
Contractors should ideally complete SAM registration in advance to avoid delays during emergency response situations.
What Triggers a Defense Contract Audit Agency (DCAA) Review?
Several factors trigger DCAA reviews of defense contracts.
Primary audit triggers include cost-type contracts, which face automatic scrutiny due to cost misallocation risks.
DCAA requirements mandate reviews when contractors submit incurred cost proposals, request progress payments, or file termination settlements.
Financial irregularities like unallowable costs, inconsistent allocation methods, or inadequate timekeeping also prompt audits.
Contract modifications involving additional funding or significant scope changes typically necessitate DCAA examination as well.
How Are Intellectual Property Rights Managed in Federal Contract Modifications?
Intellectual property rights in federal contract modifications are governed by specific FAR and DFARS clauses.
When modifications occur, contractors must reassess IP ownership based on funding sources. Government-funded work typically grants unlimited rights, while privately funded work maintains restricted rights.
Modifications may trigger renegotiation of IP terms, especially when new technical data or software is delivered. Contractors must properly mark deliverables, update SAM records, and guarantee subcontractor flow-down provisions to protect intellectual property throughout the modification process.
When Should We Establish a Government Property Management System?
A government property management system should be established before receiving any government property.
FAR 52.245-1(f) requires contractors to implement compliant systems immediately upon contract award when government property is involved. The system must meet all compliance requirements for managing, tracking, and reporting government property.
Organizations should have procedures in place for property receipt, use, maintenance, and disposition before contract execution to guarantee seamless regulatory compliance and successful property management.