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Do teaming partners and subcontractors need SAM registration?

Short Answer

Do teaming partners and subcontractors need SAM registration? Subcontractors receiving federal funding through flow-down typically need SAM registration. Teaming partners not receiving direct federal funds may not, but registration is often required by contract terms or prime contractors.

As of 2024FAR 4.1102

Detailed Answer

SAM registration requirements for team members vary: **Subcontractors - generally required:** - If subcontract exceeds $30,000 (most situations) - When receiving flow-down of federal funds - For contracts subject to FAR requirements - For reporting in FSRS (Federal Funding Accountability) **Teaming partners:** - Depends on arrangement structure - Consultants below threshold may not need SAM - Check specific contract flow-down requirements - Many primes require it regardless **Exceptions:** - Purchases under micro-purchase threshold ($10,000) - Commercial item purchases in some cases - Foreign subcontractors (different requirements) - Specific exemptions in FAR 4.1102 **Why register anyway:** - Many primes require SAM registration - Shows commitment to federal market - Required for most meaningful subcontracts - Positions for future prime opportunities - Builds credibility with prime contractors **Prime contractor requirements:** - May require SAM for all team members - Need to verify subcontractor registration - FSRS reporting requires subcontractor data - Flow-down clauses specify requirements **Small business counting:** - Subcontractor size status matters for goals - Must be registered to count toward goals - Affects prime's subcontracting plan credit - Verification through SAM registration

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