How to Verify a Federal Contractor Before Onboarding

Why federal contractor verification is required

Federal acquisition regulations require contracting officers and prime contractors to verify that entities they award work to are eligible to receive federal funds. The two primary regulatory requirements are:

• FAR 52.209-6 — Requires prime contractors to verify that prospective subcontractors at or above the simplified acquisition threshold are not excluded or disqualified. Failure to verify can result in the prime contractor being held liable for the award to an excluded entity.
• 2 CFR Part 200.213 — Requires non-federal entities (state/local governments, nonprofits, universities) receiving federal grants to verify that contractors and subcontractors are not excluded from federal programs.

Beyond regulatory requirements, verification protects your organization from supply chain disruption, payment holds, and reputational damage associated with engaging excluded or non-compliant vendors.

Step 1: Confirm active SAM registration

Any entity receiving a federal contract award, subcontract, or grant must be actively registered in SAM.gov. An expired or inactive registration is a hard blocker for payment processing in federal systems.

• Ask the contractor for their UEI — this is standard practice and a legitimate request
• Verify the UEI on sam.gov or via KnowVendor
• Check that registration status is "Active" — not expired, pending renewal, or inactive
• Note the registration expiry date and track it through the contract period
• Confirm the legal name and address match what is in your contract documents

Guide: UEI Numbers Explained: How to Verify a Federal Vendor

Step 2: Confirm CAGE code (defense and high-value contracts)

For Department of Defense contracts, subcontracts above the micro-purchase threshold, and many civilian agency contracts, the CAGE code is required alongside the UEI. Verify that the CAGE code provided by the contractor matches the SAM record and is assigned to the correct legal entity at the correct address.

Guide: What Is a CAGE Code and How to Look One Up

Step 3: SAM exclusion check

Search the SAM exclusion list using the UEI (primary) and CAGE code (secondary). This is the most critical step — an active exclusion is an absolute bar to award for federal work.

• Search by UEI first — the most reliable identifier for active registrants
• Also search by CAGE if the contractor has historical defense procurement activity
• Note the exclusion type, issuing agency, effective date, and termination date if present
• A Proposed Debarment is not an active exclusion but warrants additional scrutiny
• Document your search date and result in the contract file

Guide: How to Check if a Vendor Is SAM Excluded

Step 4: FMCSA check (transportation and logistics contractors)

For any contractor providing freight, trucking, courier, or other motor carrier services, FMCSA verification is an additional required step under DOT regulations and standard supply chain risk practice.

• Confirm active FMCSA operating authority using the contractor's USDOT number
• Verify that operating authority type covers the services being procured
• Check for any active OOS orders on the carrier
• Review safety rating if assigned — Unsatisfactory is a disqualifier

Guide: FMCSA Safety Ratings and Out-of-Service Orders

Step 5: OSHA and safety record review

For construction, renovation, manufacturing, and other field-operations contractors, OSHA inspection history provides evidence of safety culture that is not available through self-disclosure. Federal agencies increasingly use safety record data as a selection factor for construction and maintenance contracts.

• Check OSHA inspection history for the past 5 years at linked facilities
• Flag any Willful or Repeat violations — these are the highest-severity classifications
• Note inspections triggered by fatalities or serious injuries
• Assess trend — a pattern of increasing violations over time is a red flag

Guide: How to Read a Vendor's OSHA Inspection History

Putting it together: the verification record

A complete federal contractor verification record should include:

This record should be retained in the contract file and refreshed at contract renewal. For large or long-duration contracts, consider quarterly re-screening for exclusion status.