On July 29, 2012, the government launched the System for Award Management, known as SAM, which consolidated the Central Contractor Registration (CCR), the Online Representations and Certifications Application (ORCA), and the Excluded Parties List System (EPLS). CCR and ORCA are no longer accepting new or updated submissions, so contractors may be particularly interested in exploring the SAM User’s Guide to learn how to submit and revise information in this new system.
Not only does SAM look very different than CCR and ORCA, but the integration of multiple systems is going to take some getting used to. Contractors should not wait until the renewal deadline to learn how to use the system. This migration from CCR and ORCA to a single system may also provide contractors with an opportunity to examine its approach to these disclosures. Key questions include: Does my company have more registrations than it needs? Can I consolidate registrations? What steps is my company taking before making certifications that, if inaccurate, can lead to suspension, violations of the civil False Claims Act, or worse? How is my company coordinating submissions on an enterprise level to ensure consistency and accuracy?