How to Vet a Teaming Partner or Subcontractor in SAM.gov Before You Sign
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How to use SAM.gov entity and exclusion records to check a teaming partner or subcontractor, and the FAR rules that make that check your job as the prime.
Most small contractors spend a lot of time making sure their own SAM.gov record is in order and very little time looking at the records of the companies they plan to work with. That gap can hurt. When you bid as a prime and bring in a subcontractor, or when you join a team led by someone else, the other company's registration, size and exclusion status can affect whether your offer is evaluated, whether you can legally hand them work, and whether you stay inside the subcontracting limits on a set-aside. This article walks through what you can see about another company on SAM.gov, the rules in the Federal Acquisition Regulation that make checking those records your responsibility, and a simple routine for vetting a partner before you put their name in a proposal.
If your own registration is not finished yet, start with our step-by-step SAM.gov registration guide. Everything below assumes you are registered and are now deciding who to work with.
Why the prime has to care about the sub's record
The FAR is direct about who owns this question. FAR 9.104-4(a) says that, generally, prospective prime contractors are responsible for determining the responsibility of their prospective subcontractors. It adds two points that matter for a small business. Determinations about a subcontractor's responsibility may affect the Government's determination of the prime contractor's own responsibility, and a prospective contractor may be required to provide written evidence of a proposed subcontractor's responsibility. In plain terms, if you lean on a partner to meet a requirement, the contracting officer can look at that partner when deciding whether you are responsible, and can ask you to show your homework.
The general standards for responsibility are in FAR 9.104-1. They include adequate financial resources, the ability to meet the delivery or performance schedule, a satisfactory performance record, a satisfactory record of integrity and business ethics, the necessary organization, experience and technical skills, the necessary equipment and facilities, and being otherwise qualified and eligible to receive an award. A partner who fails one of those can drag your offer down with them, even if your own company is in good shape.
What SAM.gov shows you about another company
The SAM.gov Entity Information page describes the search as bringing entity information together in one place, including entity registrations, exclusions, the Disaster Response Registry, and responsibility and qualification data. The same page notes that FAPIIS.gov is now called Responsibility/Qualification inside SAM.gov, so information that used to live on a separate site is now reachable from the same search. You can choose a domain from the dropdown, such as all entity information or just responsibility and qualification records, and there is a "Show active only" option that limits results to active records.
There is one limitation worth knowing before you search. The same SAM.gov page explains that federal users must sign in with a federal email address to view registrants who have opted out of public search. That means a company can be properly registered and still not appear when you, a member of the public, search for it. If a partner does not show up, do not assume they are unregistered. Ask them for their Unique Entity ID, their CAGE code and a screenshot or printout of their active registration from their own Entity Workspace, and confirm the expiration date with them directly.
The Entity Information page also links to other free resources that help with vetting, including SBA's small business search for identifying potential small business contractors and the exclusions resources described below. SBA's search, at SBA Small Business Search, is a useful second source when you want to see how a company describes its capabilities and certifications.
Check the registration is actually active
The definition of a registered offeror in FAR 52.204-7 is the standard to measure a partner against when they will be a prime or joint venture member. Among other things, the provision says the offeror must have entered all mandatory information, including the Unique Entity ID and CAGE code, completed the Core, Assertions, Representations and Certifications, and Points of Contact sections, had all mandatory data validated by the Government, including the Taxpayer Identification Number with the IRS, and had the record marked "Active." The provision says an offeror must be registered when submitting an offer and at time of award.
For a teaming partner who will be the prime on a bid you are joining as a sub, this is their problem to solve, but it quickly becomes yours. If the prime's record lapses, the whole team's offer is at risk. For a company you plan to use as your own subcontractor, the registration rules are usually less strict, but an active, accurate registration is still a good sign that the business is organized and able to handle federal paperwork. A record that expired months ago, lists an old address or shows no points of contact tells you something about how the company runs.
Hypothetical example: a small electrical contractor in Ohio is putting together a quote on a total small business set-aside it found on our small business set-aside listings. It plans to bring in a fire alarm specialist as a subcontractor. Before writing that company into the quote, the owner searches the specialist's name on SAM.gov, finds an active record with a matching address and Unique Entity ID, and checks that there are no exclusion records. That takes about ten minutes and removes a risk that could otherwise surface after the quote is in.
Search exclusions before you sign anything
Exclusions are the check that can stop a deal outright. FAR 9.404 explains that the General Services Administration operates SAM, which contains exclusion records. An exclusion record lists the names and addresses of entities that are debarred, suspended, proposed for debarment, voluntarily excluded, declared ineligible, or excluded under the nonprocurement common rule. It also includes the agency that took the action, the cause, the effect of the action, the termination date, the Unique Entity ID, a taxpayer ID if available, and an agency point of contact.
The effect of being listed is spelled out in FAR 9.405. Contractors that are debarred, suspended, proposed for debarment or voluntarily excluded are excluded from receiving contracts, and agencies shall not solicit offers from, award contracts to, or consent to subcontracts with them unless the agency head determines there is a compelling reason. They are also excluded from doing business with the Government as agents or representatives of other contractors. The same section tells contracting officers to review the exclusion records in SAM after bids are opened or proposals and quotes are received, which means a listed partner can come to light during evaluation whether or not you looked.
The subcontracting rule is in FAR 9.405-2(b). It says contractors are prohibited from entering into any subcontract in excess of $45,000, other than a subcontract for a commercially available off-the-shelf item, with a contractor that has been debarred, suspended, proposed for debarment or voluntarily excluded, unless there is a compelling reason to do so. The contract clause that puts this into your agreement is FAR 52.209-6. When that clause is in your contract, you must require each proposed subcontractor whose subcontract will exceed the 9.405-2(b) threshold, other than a supplier of a commercially available off-the-shelf item, to tell you in writing whether it or its principals are debarred, suspended, proposed for debarment or voluntarily excluded. If you still want to use a listed party, a corporate officer or designee must notify the contracting officer in writing before entering into the subcontract, explaining the subcontractor's name, what you know about the reasons for the listing, the compelling reasons for using them anyway, and the systems you have put in place to protect the Government's interests.
For most small businesses the practical takeaway is simple. Search exclusions on SAM.gov for every partner, get the written disclosure the clause describes for any subcontract over the threshold, and keep both in your files. If you find an active exclusion, the safest choice is almost always a different partner.
Check the partner's size and status for set-aside work
On a set-aside, who you subcontract to also affects how much of the work you can hand off. FAR 52.219-14, the Limitations on Subcontracting clause, applies to contracts set aside for small business concerns, among other situations. For a services contract other than construction, the prime agrees not to pay more than 50 percent of the amount paid by the Government for contract performance to subcontractors that are not similarly situated entities. For supplies, other than procurement from a nonmanufacturer, the limit is 50 percent excluding the cost of materials, and for general construction it is 85 percent excluding the cost of materials.
The clause defines a similarly situated entity as a first-tier subcontractor, including an independent contractor, that has the same small business program status that qualified the prime for the award and is considered small under the size standard for the NAICS code the prime assigned to the subcontract. For an ordinary small business set-aside, that means any small business counts, regardless of socioeconomic status. Work that a similarly situated entity further subcontracts counts toward the prime's 50 percent limit, so you need to know whether your sub plans to hand work further down the chain.
This is where a partner's SAM.gov record helps again. Their record shows the NAICS codes they list and their size representations, which you can compare with the size standard for the code you will assign to the subcontract. Our article on NAICS codes and SBA size standards explains how those standards work, and our piece on self-certifying as a small business and size protests covers what happens when someone's size claim is challenged. A self-representation in SAM.gov is the partner's claim, not a guarantee, so if a large share of the work depends on them being small, ask how they reached that conclusion.
Hypothetical example: a woman-owned IT services firm wins a small business set-aside worth $400,000 and plans to give $180,000 of the work to a subcontractor. If that subcontractor is small under the subcontract's NAICS code, it is similarly situated and that amount does not count against the 50 percent limit. If it turns out to be other than small, the $180,000 counts, and any other non-similarly-situated subcontracts are added on top of it. Checking the sub's record and size before signing is far easier than restructuring the work after award.
Look at responsibility and performance information
The Responsibility/Qualification domain on SAM.gov is where information formerly on FAPIIS.gov now appears, according to the SAM.gov Entity Information page. When it is available for a partner, review it alongside the general responsibility standards in FAR 9.104-1. The Entity Information page also points to CPARS.gov for past performance, noting that federal users evaluate contractors there and non-federal users can view the evaluations the Government has written about them. That second part matters: you cannot pull up another company's CPARS evaluations yourself, but you can ask a serious partner to share theirs.
You can also research a partner's track record from the award side. Our guide to researching past contract awards on SAM.gov shows how to look up awards a company has received, which helps confirm that the experience a partner describes is real and recent.
A simple vetting routine
You do not need a compliance department to do this well. Before you name a partner in a proposal, search their legal name and Unique Entity ID on SAM.gov, confirm the registration is active and the details match what they told you, and save a copy of what you found with the date. Search exclusions under the company name and any other names they have used, and for subcontracts over the threshold in FAR 9.405-2(b), get the written disclosure that FAR 52.209-6 describes. For set-aside work, confirm their size under the subcontract's NAICS code and work out how their share fits within the Limitations on Subcontracting clause. Finally, check the responsibility and qualification records and ask for references or past performance evaluations you cannot see yourself.
Repeat the exclusion check right before you sign the subcontract and again from time to time during performance, since a record can change after you first look. If you are forming a longer-term relationship, our explainer on the SBA Mentor-Protégé Program covers a formal route for teaming with a larger firm.
A few minutes on SAM.gov before you sign is cheap protection. It keeps a partner's problems from becoming your problem in front of a contracting officer, and it gives you a clear record if anyone later asks how you chose who to work with.
Helpful reading. For teaming and subcontracting, see government contracting teaming agreement books (Affiliate link) and federal subcontracting books (Affiliate link). As an Amazon Associate I earn from qualifying purchases.
The Set-Aside Desk is published by SetAside Signal, an independent publication, not a government agency. This article isn't legal advice; rules change, so confirm details with the official sources: SBA (sba.gov), SAM.gov and the FAR at acquisition.gov. Published Oct 28, 2026.