SAM Registration Update: Notarized Letter Requirement Change and New Deadline Looming

June 13, 2018

By Antonio R. Franco
Practice Areas: Government Contracts Law and Small Business Programs & Advisory Services

As most government contractors may know by now, in order to proactively fight against alleged fraudulent activity in the System for Award Management (SAM), the General Services Administration (GSA) issued a rule that required all entities to “provide an original, signed notarized letter stating that you are the authorized Entity Administrator before your registration will be activated.” On June 11, 2018, GSA issued an update to the notarized letter requirement in two parts.

The first, which went into effect on June 11, 2018, applies to entities “who create or update their registration in SAM.gov to apply only for federal assistance opportunities such as grants, loans, and other financial assistance programs.” These entities no longer need to have an approved Entity Administrator notarized letter on file before their registration is activated. 
 
The second, which goes into effect on June 29, 2018, applies to “all non-Federal entities who create or update their registration in SAM.gov, and these entities also no longer need to have an approved Entity Administrator notarized letter on file before their registration is activated.” It is important to note that all entities, regardless of their purpose of registration, must mail the original and signed notarized letter to the Federal Service Desk within thirty (30) days of activation or risk having their registration deactivated. 
 
Additionally, in support of its continuing efforts to increase security and to prevent fraudulent activity, GSA is implementing a new login process for SAM.gov which takes effect on June 29, 2018.  As a result of the new process, all users attempting to log in to SAM.gov on or after June 29, 2018 will be automatically directed to create a Login.gov user account.  Importantly, the current SAM.gov username and password will no longer work and users will be unable to access SAM.gov until they have created a Login.gov account.  In order to create a Login.gov account users need:
  1. The email address and password associated with their SAM.gov account;
  2. Access to the above mentioned email account for all confirmation emails; and
  3. A working telephone that can receive the security code sent from Login.gov.
For further assistance with creating a new account, please visit Login.gov. As a caveat, it is important for users to utilize the email address that is currently associated with their SAM.gov account. Using the same email address will allow Sam.gov to automatically migrate the user’s role from SAM to Login.gov account.  Although a user can choose to use a new and distinct email address for their Login.gov account, the entity roles currently assigned in SAM will not automatically migrate and users will be required to manually assign entity roles which could create unnecessary delays when updating existing registrations. If a user does not remember which email address is associated with their current SAM.gov account, or if a user needs to update the email address associated with their SAM.gov account, the user can view and update their account settings at www.SAM.gov. All users must be cognizant of the impending deadline of June 29, 2018. Once this date passes, all SAM.gov usernames and passwords will be de-activated and users will no longer be able to access their accounts with those credentials.
 
About the Author: Tony Franco is a senior partner with PilieroMazza and oversees the Government Contracts and Small Business Programs & Advisory Services Groups. He may be reached at afranco@pilieromazza.com. Jess Goodall, a paralegal with PilieroMazza, also contributed to this article.
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