S02 FAR DEVIATION FEB 2025 NOTICE.pdf
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- Solicitation number
- 36C24226B0014
About this file
This is a Federal Acquisition Regulation (FAR) Deviation Notice issued in February 2025 addressing a systems-versus-policy alignment issue.
The notice clarifies that the System for Award Management (SAM) may continue to require entities to complete representations and certifications based on provisions that are no longer included in federal agency solicitations. Specifically cited examples include FAR 52.222-25 (Affirmative Action Compliance) and paragraph (d) of FAR 52.212-3 (Offeror Representations and Certifications for Commercial Products and Commercial Services). The notice establishes that contracting officers will not consider these outdated representations when making award decisions or enforcing contractual requirements. Additionally, entities are neither required to nor able to update their SAM registrations to remove these representations, addressing the technical lag between system capabilities and current policy requirements.
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FAR DEVIATION FEB 2025 NOTICE
“System updates may lag policy updates. The System for Award Management (SAM) may continue to require entities to complete representations based on provisions that are not included in agency solicitations. Examples include 52.222-25, Affirmative Action Compliance, and paragraph (d) of 52.212-3, Offeror Representations and Certifications—Commercial Products and Commercial Services. Contracting officers will not consider these representations when making award decisions or enforcing requirements. Entities are not required to, nor are they able to, update their entity registration to remove these representations in SAM.”
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