Just over a month ago, we wrote about a new verification requirement in the form of a notarized letter for new entities registering on SAM.gov, a registration that is required for companies that do business with the federal government. At that time, the requirement was only applicable to new registrations. However, according to an April 26, 2018, update on GSA’s website, the requirement is now applicable to “existing registrations being updated or renewed in SAM,” effective April 27, 2018.

As discussed in the prior blog, the requirement for an original, signed, and notarized letter identifying the authorized Entity Administrator for the entity associated with the DUNS numbers was put into effect to reduce the amount of suspected fraudulent activity in SAM.gov. If your company’s registration was thought to have been affected by the fraudulent activity, you should have already been notified, and your account should have been deactivated. Still, we encourage all entities registered in SAM to review their registration information, particularly their financial information.

If you are seeking to register a new entity, to reactivate your account, or to update or renew your existing registration, you must now follow the notarized letter process. The criteria for the notarized letter are explained on the Federal Service Desk’s (“FSD”) website, and FSD has templates that can be accessed through this link. It is critical to follow the templates when composing the letter and to ensure that all information therein is accurate. According to FSD’s website, the main causes of rejection of a letter are failure to include a statement clarifying the account administration preference, information in the letter that does not match the information in SAM.gov, and failure to include all nine digits of the DUNS number. If your letter is rejected, you will be required to submit another notarized hard copy.

Understanding the additional time that this verification process will add to new and existing registrations is important as the letter must be mailed to FSD, processed, and approved. It is still unclear exactly how much time this process will add to new and existing registrations. You should build in as much time as possible for this process to ensure that your SAM registration is not only active prior to award but, as of April 27, 2018, to ensure that your registration does not expire so that you may continue to receive payments.

If you have any questions regarding the SAM.gov registration process, update, or renewal requirements or if you would like assistance with the notarized letter process, please do not hesitate to contact us.

About the Author: Meghan Leemon is an associate with PilieroMazza in the Government Contracts Group at our Colorado office. She may be reached at [email protected].