All government contractors must have an active registration in the System for Award Management (SAM) to do business with the government. As of March 22, 2018, SAM requires users registering a new business entity to "provide an original, signed notarized letter" confirming that they are the "authorized Entity Administrator" before their registration will be activated. Starting April 27, 2018, the requirement will be extended to existing registrations being updated or renewed. Contractors should plan ahead for possible delays resulting from the new requirement.
Only individuals authorized to represent a particular government contractor may register the entity in SAM. GSA's Office of Inspector General is investigating alleged fraudulent activity related to SAM. The new requirement to submit "an original, signed notarized letter identifying the authorized Entity Administrator for the entity associated with the Data Universal Numbering System (DUNS) number before the registration will be activated" is part of an effort to prevent future fraudulent activity.
The completed, signed, and notarized letter must be mailed to the Federal Service Desk (FSD). A contractor's registration will not be activated until after FSD receives, processes, and approves the letter. This additional step in the registration process will likely extend the amount of time it takes for SAM registrations to be activated. Therefore, contractors should expect delays and plan accordingly. The requirements for this letter are outlined on the FSD's website, including links to letter templates.
*Victoria Dalcourt is a Law Clerk in our Washington, D.C. office and not admitted to the bar.
Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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