In order to do business with the federal government, you must register through the System for Award Management, or SAM.gov, and obtain a Unique Entity Identifier (UEI). This is a requirement for all GSA Schedule contractors before they begin preparing their offer, and it’s important you know how to navigate the registration and renewal process correctly. This will save you time in the long run in case there are errors in your registration, and you have to go back and fix them. In this blog, we’ll cover some of the aspects of SAM registration companies may overlook or be confused about so you can be prepared when the time comes for registration or renewal.
SAM Ownership
One of the main goals of SAM.gov is to identify the ownership and control of businesses in connection with the federal government. One important aspect of SAM is that it requires businesses to provide information about their ownership structure. If you’ve spent time familiarizing yourself with SAM, you may have encountered two types of ownership categories to promote government transparency. If your company is ultimately owned or controlled by an individual, a partnership, a corporation, a Joint Venture (JV), or an agent, then that company would be considered the "Highest-Level Owner."
On the other hand, if your company is owned by a company that has direct control, it would be categorized as the "Immediate Owner". Unlike the highest-level owner, the immediate owner is one level below the ownership chain. What are some indicators of control? This can include companies sharing facilities and equipment, family members having a common identity of interest, or shared use of employees. If you have an owner that fits within the above definitions, they will be required to obtain a CAGE Code.
Importance of CAGE Codes
As mentioned, Commercial and Government Entity (CAGE) Codes are required for all GSA contract holders. These codes are assigned by the Department of Defense's (DoD) Defense Logistics Agency (DLA) and they represent your company's physical address and are essential for the following reasons:
- Tracking and managing contracts
- Tracking GSA mailings and placed orders (forwarded payments)
- Tracking shipments between the DoD and its suppliers
- Maintaining administrative records
- Tracking the affiliations between companies
If this information can’t be tracked, you won’t be able to do business with GSA. You also won’t be able to finalize a pending Name Change modification until your SAM registration is completely up to date. Make sure that you take the required steps before your registration’s expiration date to have your owners obtain CAGE Codes. If your SAM registration is up for renewal, we highly recommend listing your highest-level and immediate owners before completing the registration. Let’s discuss the requirements for re-registering in SAM under a new name.
Re-registering in SAM Under a New Name
As previously stated, all SAM.gov registrants are required to be updated annually. If you are registering under a new name, you will need to upload a signed name change agreement as validation of the new name. In certain instances, an attachment of an IRS confirmation document can be used for entity validation of the new name. Once you’ve sorted out which validation document you’d like to use, you can proceed to renew your registration using the instructions below:
- Log into SAM.gov.
- Find the record of your entity that needs to be updated. Click on the three vertical dots and select the "Update" option.
- A question will appear asking what your relationship is with this entity. Be sure to select “I am an employee or officer of this entity”.
- Be sure that you’ve marked “I am an employee or officer of this entity” and select next.
- A guide will be available to download if you need assistance.
- You will then be taken to a page where it will ask you if you would like to update/renew your entire Entity Registration. Make sure this is selected and hit next.
- Select and Confirm CAGE code for your entity.
- Continue to select “next” to provide documented proof of your new legal business name. This is where you can use an IRS confirmation document.
- You’ll then be taken to a Register Entity portal where you can enter all your remaining information, including your company’s new name. This should be straightforward as long as all of the information you’re entering is accurate/verified.
- Select “Submit” at the end to complete your renewal.
- After completing this process, be on the lookout for incoming notifications from SAM or the DLA for any further information requested. Be sure to respond to them within 10 days upon receiving their message.
Do You Need Help With Your SAM Registration?
You need to ensure that your SAM.gov profile displays accurate information to maintain transparency with the government. Failure to disclose information properly increases the risk of corporate exposure or fraud. We understand that navigating SAM and completing registration renewals can be overwhelming. However, with proper preparation and guidance, the process becomes manageable. Our consultants are here to assist you every step of the process. Our guidance includes walkthroughs of the GSA Schedule acquisition process and the necessary deliverables as required from your Contracting Officer or Specialist.
