Breaking Into Federal Technology Work: The First Ninety Days

A good engineer with a working product can go years without ever selling to the federal government, not because the door is closed but because nobody tells them where it is. The advice available online tends to be either a sales pitch for a registration service or a vague encouragement to "build relationships." Neither one gets a first invoice paid.

This article is the mechanical version: which identifiers you need and in what order, how to pick the codes that determine who can find you, where requirements are published, what a first win realistically looks like, and why the past-performance objection stops more people than it should. It ends with a ninety-day sequence that produces a submitted bid rather than a folder of research.

The shape of the problem

Federal buying is tiered by dollar value, and the tiers behave like different markets. The small tier has few clauses, no formal source selection, and a competition standard a two-person firm can meet. The large tier rewards incumbency, bid teams, and a decade of documented performance.

New entrants almost always aim at the wrong tier. They open a 180-page request for proposals on SAM.gov, read the past-performance section, conclude they are ineligible, and quit. The requirement they could have won was a $60,000 purchase order that never generated a press release.

So the working assumption for year one: your target is a requirement at or below the simplified acquisition threshold, currently $350,000 under FAR 2.101, or a research award such as an SBIR Phase I where evaluation turns on technical merit rather than corporate history. The threshold mechanics are worth learning cold, and we cover them in the simplified acquisition threshold, explained.

The registration chain, in order

The order matters because each step depends on the one before it. Doing them out of sequence is the most common reason a registration stalls for a month.

1. A legal entity with a consistent name and address. Settle on the exact legal name on your formation documents and the exact physical address. Not a P.O. box. That string has to match your IRS records, your bank, and your SAM registration character for character, because a firm that banks under a slightly different spelling than it files under will spend weeks in validation.

2. An EIN from the IRS. Free, applied for online, issued the same session in most cases. You need it for the bank account and for SAM.

3. A business bank account. The government pays by electronic funds transfer, so SAM asks for a routing number and account number. The account name should match the legal name.

4. Entity validation and the UEI, at SAM.gov. The Unique Entity ID is a twelve-character alphanumeric identifier that replaced the DUNS number governmentwide on April 4, 2022. It is issued inside SAM.gov at no cost. First, GSA's entity validation service checks that your legal name and physical address are real and match documentation; if the automated check fails, you upload proof such as articles of organization or a utility bill in the entity's name. This is the longest step, and it runs longer for brand-new companies whose records have not propagated yet.

5. Full entity registration in SAM. A UEI alone does not make you eligible for award. Completing the registration adds taxpayer information, banking data, your NAICS codes, points of contact, and the annual representations and certifications at FAR 52.204-8. FAR 4.1102 requires registration at the time you submit an offer or quotation, and FAR 52.204-7 requires it to stay active through award, performance, and final payment. It expires annually. An expired record is the most common way a small firm loses an award it had already won on the merits.

6. The CAGE code. The Commercial and Government Entity code is a five-character identifier assigned by the Defense Logistics Agency. You do not apply for it separately. Completing a SAM registration as a U.S. entity triggers the request automatically, and DLA assigns it during processing. Entities located outside the United States receive an NCAGE code through the NATO system instead.

7. Socioeconomic certifications, if they apply. Some designations are self-certified in SAM. Four cannot be, for set-aside purposes, and require an application to SBA: 8(a), HUBZone, women-owned small business, and service-disabled veteran-owned small business. Certification authority for veteran-owned firms moved from VA to SBA on January 1, 2023, and the grace period for previously self-certified firms closed at the end of that year. If you qualify, start early. The process is slow and it changes which competitions you can enter.

None of this costs money. SAM.gov registration, the UEI, and the CAGE code are all free. Firms that charge several hundred dollars to "register your business with the government" are filling out the same public forms you can. Paying for help is a legitimate choice; paying because you believed a fee was required is not.

Choosing NAICS codes

The North American Industry Classification System is a six-digit code set that describes what a business does. In federal contracting it does two jobs, and confusing them causes real errors.

The first job is discovery. Contracting officers and market researchers filter SAM.gov and SBA's Dynamic Small Business Search by NAICS. If your record does not carry the code a buyer searches on, you do not exist to that buyer. List every code that honestly describes work you can perform; there is no penalty for listing several.

The second job is sizing. SBA publishes a size standard for each code at 13 CFR 121.201, expressed either as average annual receipts or as an employee count. The common technology codes:

NAICS	Description	Size standard
541511	Custom Computer Programming Services	$34.0M receipts
541512	Computer Systems Design Services	$34.0M receipts
541513	Computer Facilities Management Services	$34.0M receipts
541519	Other Computer Related Services	$34.0M receipts, with a separate employee-based exception for IT value-added resellers
541715	Research and Development in the Physical, Engineering, and Life Sciences	1,000 employees, with higher exceptions for certain aerospace work
518210	Computing Infrastructure Providers, Data Processing, Web Hosting, and Related Services	Receipts-based; check the current table

Common technology NAICS codes. SBA adjusts these figures periodically, so 13 CFR 121.201 controls.

Receipts are not last year's revenue. Under 13 CFR 121.104, size is computed on a five-year average of annual receipts, a change from the older three-year rule that became mandatory in January 2022. A firm with one large year stays small longer under the five-year average.

One nuance that catches people: you do not choose the code for a given solicitation. Under FAR 19.303 the contracting officer assigns one code and its size standard to each acquisition, and that assignment decides whether you are small for that competition. Your SAM list governs discoverability, not eligibility. If a solicitation carries a wrong code, SBA's Office of Hearings and Appeals hears NAICS appeals, and the window is ten calendar days after issuance.

Where the work is actually posted

There is no single feed, and the free sources are better than most people assume.

• SAM.gov Contract Opportunities is the governmentwide point of entry. FAR 5.101 requires contracting officers to synopsize proposed contract actions expected to exceed $25,000 there, and to publicly display actions between $20,000 and $25,000 for at least ten days. That rule has a consequence worth internalizing: a $19,000 buy has no posting requirement at all, so watching a feed will never surface it. That money goes to firms the contracting shop already knows about.
• Sources sought notices and requests for information are posted in the same place and are the highest-value item on it for a new firm. They are market research under FAR Part 10, they cost you a two-page response, and they are how a requirement gets shaped before it is competed. Answering them is the closest thing to a free move in this business.
• SBIR and STTR topics. Eleven agencies participate. DoD publishes and receives proposals through the Defense SBIR/STTR Innovation Portal at dodsbirsttr.mil; other agencies use their own systems, and sbir.gov aggregates open topics. Eligibility runs through 13 CFR 121.702: more than 50 percent directly owned and controlled by U.S. citizens or permanent resident aliens, and no more than 500 employees.
• Grants.gov for assistance awards, a different instrument with different rules but sometimes the right fit for research work.
• USAspending.gov is not an opportunity feed. It is the record of what was bought, by which office, from whom, at what price, and it is the most useful free market-research tool the government publishes.
• GSA eBuy carries a large volume of task orders, but you need a Multiple Award Schedule contract to see and bid them. That onboarding takes months, which makes it a year-two move. GSA's Startup Springboard path does let the professional experience of key personnel substitute for the usual two-year corporate experience requirement, so a young firm is not automatically excluded.

Two human channels matter as much as the portals. Every agency has a statutorily required Office of Small and Disadvantaged Business Utilization whose job is exactly this. And APEX Accelerators, the network formerly called Procurement Technical Assistance Centers and renamed in 2023 under the DoD Office of Small Business Programs, give free one-on-one counseling to firms entering the market, with coverage in nearly every state.

What a realistic first win looks like

Four patterns account for most first awards to technology firms with no federal history.

A micro-purchase. At or below $15,000, a federal cardholder can buy from you without soliciting competing quotes, provided the price is reasonable. No posting, no evaluation, no protest. The practical requirement is being easy to buy from: accept a card, produce a fixed-price quote on letterhead, and match your receipt name to your SAM record.

A purchase order below the simplified acquisition threshold. Between $15,000 and $350,000, FAR 13.003(b)(1) reserves the acquisition for small business when the contracting officer reasonably expects offers from at least two responsible small firms. The process is FAR Part 13: informal competition, no source selection board, no written discussions. This is the widest realistic lane.

A subcontract. Under FAR 19.702, an other-than-small prime receiving a contract above $900,000 generally has to submit a subcontracting plan with small business goals. Those goals are real and primes need credible small firms to meet them. A named subcontractor role on a winning proposal gives you performance history without carrying the compliance weight of a prime.

An SBIR or STTR Phase I. The statutory evaluation criteria are technical merit, the qualifications of the principal investigator and the team, and commercial potential. Corporate past performance is not among them. For a strong engineer with no federal history, this is the single most level competition in the federal system, which is also why it is crowded.

Why past performance is not the wall

Nearly every new entrant believes the same thing: you cannot get a contract without past performance, and you cannot get past performance without a contract. It is a real problem in large competitive negotiations. It is much weaker than people think in the range where a new firm should be bidding, for four separate reasons.

First, the rule for offerors with no record is neutrality, not penalty. FAR 15.305(a)(2)(iv) says that in the case of an offeror without a record of relevant past performance, or for whom information is not available, the offeror may not be evaluated favorably or unfavorably on past performance. Having no history is not a deduction. It is a blank.

Second, other people's history can count as yours. FAR 15.305(a)(2)(iii) directs the government to consider the past performance of predecessor companies, of key personnel who have relevant experience, and of subcontractors that will perform major or critical aspects of the requirement. The twelve years your lead engineer spent modernizing claims systems is evaluable experience. Say so explicitly, with the customer, the scope, and the dates.

Third, simplified acquisitions rarely run a formal past-performance evaluation at all. FAR Part 13 does not require the Part 15 apparatus. Many sub-threshold requests for quotation are decided on technical acceptability and price.

Fourth, what actually gates award at that level is responsibility, not history. Before awarding, the contracting officer must find the firm responsible under FAR 9.104-1: adequate financial resources, ability to meet the delivery schedule, a satisfactory record of integrity and business ethics, the necessary organization and technical skills, and eligibility. And if a contracting officer proposes to reject a small business's offer on responsibility grounds, FAR 19.6 requires referral to SBA, which may issue a Certificate of Competency that the contracting officer must accept. A small firm gets a second decision-maker on that question, which few new entrants know.

One honest caveat. Under FAR 42.1502, CPARS evaluations are generally required only above the simplified acquisition threshold, so a $70,000 purchase order will not create a CPARS record. What it creates is a contracting officer and a program manager who know your name and will answer a questionnaire. Ask for that reference in writing at closeout, while everyone still remembers the work.

The ninety-day sequence

The point of a schedule is that research stops being a substitute for bidding. Here is a sequence that ends in a submitted proposal.

The mistakes that cost the most time

Letting SAM lapse. Registration expires annually. Firms have been found ineligible for award on requirements they had already won technically. Calendar the renewal sixty days out.

Name and address drift. Every mismatch between IRS records, banking records, and SAM adds a validation cycle. Fix them once, at the start.

Bidding the wrong tier. A firm with no federal history submitting on a full-and-open, best-value negotiated procurement against three incumbents is buying an expensive lesson. That is not humility, it is arithmetic.

Treating registration as marketing. An active SAM record makes you eligible, not visible. Visibility comes from sources sought responses, a searchable DSBS profile, and contracting officers who have your capability statement on file.

Waiting for a perfect solicitation. A requirement that matches your product exactly and has no incumbent is rare. Bid the near fits and let the second and third bids be better than the first.

The entry mechanics are learnable in a quarter. Judgment about which requirements are winnable takes longer, and the only way to build it is to read solicitations and submit bids. Start the registration this week so the calendar is not what holds you back ninety days from now.

This article is general education, not legal advice. Regulations change and the terms of a specific solicitation control. Confirm current figures and clause text at acquisition.gov before relying on them.