Sunday, October 13, 2024

SmallGovCon: Keep Registrations in SAM Current to Avoid Loss of SDVOSB Verification

“The decision in Bravo Federal Consulting, LLC, SBA No. CVE-213 (Dec. 1, 2021) is both an important reminder of the importance of keeping all database information up to date and a cautionary tale of the unfortunate consequences that can happen when you don’t. In that decision, SBA’s Office of Hearings and Appeals (OHA) denied an appeal by Bravo Federal Consulting, LLC (Bravo). Bravo submitted a request to change its name, setting off a chain of events that ended in Bravo losing its verified status as a service-disabled veteran-owned small business (SDVOSB).

On July 1, 2021, Bravo submitted to the Department of Veterans Affairs Center for Verification and Evaluation (CVE) a request to change its name from Pro Gov Solutions, LLC to Bravo Federal Consulting, LLC. Unfortunately, Bravo had not registered in the System for Award Management (SAM) as Bravo Federal Consulting, LLC, so CVE was unable to verify its status as an SDVOSB. All applicants for VIP Verification must be listed in SAM prior to application submission per 38 C.F.R. § 74.2. Additionally, because Bravo had not registered under the name Bravo Federal Consulting, LLC prior to the name change, it had failed to maintain eligibility as required under 38 C.F.R. § 74.15(b) which requires participants to inform CVE of any changes that would affect eligibility within 30 days of the change…”

“Ultimately, Bravo did not include a statement of why the cancellation was in error. As such, OHA determined Bravo had failed to comply with the regulation and failed to respond to the NOPC leading to the appeal being denied. OHA concluded that Bravo was not listed in SAM, which is an SDVOSB requirement, and it was proper for CVE to remove Bravo as an SDVOSB.

In the end, Bravo Federal Consulting, LLC should serve as a cautionary tale for all small businesses involved in federal government contracting. Ensure that your business has the most up to date information in SAM and remain in compliance by reporting any change that may affect eligibility within the required time. While this case involved an SDVOSB, keeping the SAM registration is important for all types of federal contractors…” Read the full article here.

Source: Keep Registrations in SAM Current to Avoid Loss of SDVOSB Verification – By Stephanie Ellis, December 28, 2021. SmallGovCon.

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Jackie Gilbert
Jackie Gilbert
Jackie Gilbert is a Content Analyst for FedHealthIT and Author of 'Anything but COVID-19' on the Daily Take Newsletter for G2Xchange Health and FedCiv.

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