What is Ownership of Offeror (OoO) & IO & HLO?

Ownership of Offeror (OoO)

What is OoO?

The Department of Defense (DOD), General Services Administration (GSA) and National Aeronautics and Space Administration (NASA) have revised the FAR that now requires that offerors provide their CAGE codes to contracting officers and that, if owned or controlled by another entity, offerors will provide, in a new provision with their representations and certifications, the CAGE code of such entity.

What is the Federal Acquisition Regulation Subpart 4.18?

This subpart of the FAR effective November 1, 2014 prescribes policies and procedures for identifying Commercial and Government entities. This new subpart will help the U.S. Government better understand:

Federal spending patterns across corporations
Traceability in tracking performance issues across corporations
Contractor personnel outside the U.S.
Supply chain traceability and integrity efforts

What is an Offeror?

For the purposes of completing FAR 52.204-17, an Offeror is an entity that submits an offer to the U.S. Government. An offer means a response to a solicitation that, if accepted, would bind the Offeror to perform the resulting contract. The entity registering in SAM is considered to be the Offeror.

What is an Immediate Owner (IO)? (Reference FAR 4.1801(2))

The IO is an entity, other than the Offeror, that has direct control of the Offeror. Indicators of control include, but are not limited to, one or more of the following:

Ownership or interlocking management
Identify of the interests among family members
Shared facilities and equipment
Common use of employees

What is a Highest-Level Owner (HLO)? (Reference FAR 4.1801(2))

An HLO is the entity that owns or controls an IO of the Offeror, or that owns or controls one or more entities that control an IO of the Offeror. No entity owns or exercises control of the HLO.

How does my entity’s IO and/or HLO get a CAGE code?

If the CAGE code of your entity’s IO and/or HLO is not found in CSI, your IO and/or HLO must get a CAGE code assigned in one of two ways:

If the HLO or IO plan on doing business with the U.S. Government, they must register in SAM and a CAGE code will be assigned during processing.
If the HLO or IO does NOT plan on doing business with the U.S. Government, they may register at Request or Update your CAGE code.

My entity has an IO and/or HLO. However, they are not located in the U.S. or its’ territories and don’t do business with the U.S. Government. Do I still need to obtain and/or report a CAGE code for them?

Yes, entities which have an IO and/or HLO located outside the U.S. or its’ territories require a CAGE code. These types of CAGE codes are referred to as an NCAGE code.

NCAGE code requests for assignment or updates will be submitted using the NSPA NCAGE Request Tool.