Electrical Contractor Protests Lack of SAM NAICS Codes

After a ruling by the Government Accountability Office (GAO), a common misconception was uncovered concerning the lack of appropriate assigned NAICS codes listed under its Small Business Administration (SBA) system for the Award Management (SAM) profile. Small business contractors identity specific areas of experience and expertise in their SAM profile using the NAICS (North American Industry Classification System) codes. In most cases, contractors list all SAM NAICS codes in which they hope to perform work.

In a recent case, Veterans Electric, LLC, B-413198 (Aug. 26, 2016) —it was found that an awardee’s failure to list the assigned NAICS code under its SAM profile did not make its proposal technically unacceptable. Two contractors, Veterans Electric and Architectural Consulting Group submitted proposals for upgrades at the Wood National Cemetery. The solicitation was earmarked for a veteran-owned small business. After reviewing proposals, the VA awarded the contract to Architectural Consulting Group.

The VA issued the solicitation under NAICS code 238210 (Electrical Contractors and Other Wiring Installation Contractors), which carries a size standard of $15 million. Protesting the award, Veterans Electric challenged their competitor on two related issues: first, failure to include NAICS code 238210 in its SAM profile and second, the failure to certify that it met the relevant size standard rendered its proposal.

In response, the GAO wrote: “So long as a company meets the applicable size standard, we are aware of no statutory or regulatory requirement that it have the particular NAICS code identified in the solicitation as its primary code.” Because Architectural Consulting Group listed several other NAICS codes at or below the relevant $15 million size standard, it complied with the size standard for this procurement. Veterans Electric did not present any evidence to show otherwise, therefore, the contracting officer’s determination was considered reasonable.

Do you have all the appropriate SAM NAICS codes to secure related bids? If you have questions about your SAM profile and NAICS codes to represent your business, contact KDuncan & Company for more information.


KDuncan & Company is dedicated to providing knowledge and support for small government contractors about concerns regarding government contracting. For questions on areas such as as cost proposals, accounting systems, DCAA compliance, and incurred cost audits, reach out to KDuncan & Company.

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