Question:
It’s not clear to me whether we should go with a Full or Temporary SAM Deviation. If we go with a Temporary, it seems that the expert will still need to register with SAM, which is the source of this problem.
Answer:
The Temporary SAM Deviation will allow the Contracting Officer to create a contract while the vendor completes their SAM Registration.
With a temporary SAM deviation, the expert will need to be “Actively” registered in SAM prior to submitting an invoice. Full SAM Deviations are very rare. Typically I recommend the temporary SAM deviation route, as it gives the Expert more time to register.
The Full SAM Deviation will also allow the Contracting Officer to create a contract. The difference is the vendor is not required to create a SAM Registration but is required to complete via hard copy their Representations and Certifications.
Please keep in mind for both the temporary and full SAM deviations, you will need to include information in the memos on the other experts you contacted and why you couldn’t find/use someone already registered in SAM. Your Contracting Officer will likely not approve without this information. A full SAM deviation would be used if it’s the only expert in the field of expertise you require and they have refused to register, so you have no other alternative.