While many government contractors make good faith efforts to comply with contract clauses and navigate other federal contract requirements, sometimes there is no pat answer depending on the CO and the specific circumstances of a given situation.  The Government Accountability Office (GAO) recently provided a great example of this when it ruled that a company with a temporarily lapsed SAM registration should not have been excluded from a competition because the government failed to include the proper FAR clause requiring offerors to be current on it.  GAO stated that there is no requirement for mandatory provisions to be incorporated into solicitations by operation of law if they are omitted from the solicitation document.  This lies in stark contrast to several other GAO rulings that did require an offeror to be registered in SAM at the time offers were to be submitted.  In addition, it potentially creates another kink in the application of the Christian Doctrine, a long-held precept that says that clauses not included in a solicitation should be considered as included if their inclusion was required by statute.  Acquisition policy isn’t always clear, either.  A recent GSA response to a question on whether and how a specific employment tracking requirement could be applied drew a response saying that the contracting officer overseeing a procurement is the only one authorized to interpret the FAR for that procurement.  As contractors know, however, interpretations of FAR clauses vary from CO to CO, even within the same agency or department.  In addition, CO’s have been known not to remember why or how they made a specific interpretation years later when a contractor is facing an audit or False Claims Act action.  The bottom line for contractors is that they simply can’t ask enough questions, even when they think they already know the answer.  In addition, getting CO responses in writing is absolutely essential.  Even though this may seem tedious and add time to the conduct of business, remember that there is no “it depends” on how the compliance community will view any potential transgressions.