FAR 18.102—System for Award Management.
Plain-English Summary
FAR 18.102 addresses limited exceptions to the normal SAM registration requirement and explains how contracting officers should use SAM’s Disaster Response Registry during emergencies. It covers three situations where contractors do not have to be registered in the System for Award Management at the time they submit offers or quotations: awards made without full and open competition because of unusual and compelling urgency, awards made by a contracting officer deployed in military operations, and awards made by a contracting officer located outside the United States and its outlying areas in support of diplomatic or developmental operations in a State Department danger pay post or in the conduct of emergency operations. The section also makes clear that, even when pre-award SAM registration is not required in these situations, contractors must still be registered in SAM to access the Disaster Response Registry. Finally, it directs contracting officers to consult the Disaster Response Registry in SAM to identify available contractors for debris removal, distribution of supplies, reconstruction, and other disaster or emergency relief work inside the United States and its outlying areas. In practice, this section balances speed and flexibility in urgent or overseas contingency situations with the government’s need to locate capable vendors quickly during disasters.
Key Rules
SAM not always required at offer
Contractors do not have to be registered in SAM when submitting offers or quotations for certain urgent or contingency awards. This exception applies only to the specific situations listed in the rule and does not eliminate other applicable registration requirements.
Urgency exception for awards
The SAM pre-offer registration requirement does not apply to contracts awarded without full and open competition because of unusual and compelling urgency. This recognizes that immediate procurement needs may make advance registration impractical.
Deployed and overseas exceptions
The rule also waives pre-offer SAM registration for awards made by contracting officers deployed in military operations, or located outside the United States and its outlying areas for diplomatic or developmental operations in a designated danger pay post, or during emergency operations. These are operationally constrained environments where rapid award actions may be necessary.
SAM needed for Disaster Response Registry
Even though pre-award registration may be waived in the listed circumstances, contractors must be registered in SAM to access the Disaster Response Registry. Registration is therefore still necessary for contractors who want to be considered for disaster-response opportunities through that registry.
Use Disaster Response Registry
Contracting officers must consult the Disaster Response Registry in SAM to find contractors for debris removal, supply distribution, reconstruction, and other disaster or emergency relief activities inside the United States and its outlying areas. This supports rapid market research and source identification during emergencies.
Responsibilities
Contracting Officer
Determine whether one of the listed exceptions applies before requiring SAM registration at the time of offer or quotation submission. In disaster or emergency situations inside the United States and its outlying areas, consult the Disaster Response Registry in SAM to identify available contractors for relevant relief work.
Contractor
Understand that SAM registration may not be required at the moment of offer submission in the limited situations covered by this section, but maintain SAM registration if seeking access to the Disaster Response Registry. Be prepared to register in SAM when required for award administration or registry access.
Agency
Support contracting officers by ensuring procedures and tools are available to use SAM and the Disaster Response Registry effectively during emergencies, contingency operations, and disaster response actions. Maintain awareness of the special acquisition flexibilities and related policy references.
Practical Implications
This section is mainly about speed: in urgent, deployed, overseas, or emergency situations, the government can move forward without waiting for pre-offer SAM registration.
Contractors should not assume the exception is broad; it is limited to the exact circumstances listed, so normal SAM rules still apply in most procurements.
A common pitfall is confusing the waiver of pre-offer registration with a waiver of all SAM-related requirements; the rule only addresses registration at the time of offer or quotation for the specified actions.
For disaster response work, being in SAM matters because it is the gateway to the Disaster Response Registry, which contracting officers are directed to use for locating vendors.
Contracting officers should document why an exception applies and should actively search the Disaster Response Registry when procuring debris removal, supplies, reconstruction, or similar emergency services.
Official Regulatory Text
(a) In accordance with 4.1102 , contractors are not required to be registered in the System for Award Management (SAM) at the time of submission of offers or quotations for— (1) Contracts awarded without providing for full and open competition due to unusual and compelling urgency (see 6.302-2 ); or (2) Contracts awarded by a contracting officer– (i) Deployed in the course of military operations; (ii) Located outside the United States and its outlying areas, for work to be performed in support of diplomatic or developmental operations, in an area that has been designated by the Department of State as a danger pay post; or (iii) In the conduct of emergency operations. (b) However, contractors are required to be registered in SAM in order to gain access to the Disaster Response Registry. (c) Contracting officers shall consult the Disaster Response Registry via https://www.sam.gov ., Search Records, Advanced Search, Disaster Response Registry Search to determine the availability of contractors for debris removal, distribution of supplies, reconstruction, and other disaster or emergency relief activities inside the United States and outlying areas. (See 26.205 ).