Updates to SAM.gov

As a federal contractor, you may think you are well acquainted with the System for Award Management (SAM) platform. After all, contractors must keep an active registration in SAM.gov to be eligible for contracting opportunities from federal customers. To keep an active registration, you need to regularly, at least annually, update and renew your company’s SAM registration. However, since many contractors only login to SAM.gov once a year to complete this, you may be shocked by the number of changes to SAM.gov over the past year. As such, I will be going over some of these changes so that you are prepared the next time you log in to SAM.gov.

Switch from DUNS Number to SAM Unique Entity Identifier (UEI)

The first major change in SAM is a move away from the use of the Data Universal Numbering System (DUNS) number. Contractors used to have to apply for a DUNS number through the third party Dun & Bradstreet if they wanted to be verified in SAM.gov. As of April 4, 2022 however, SAM’s internal 12-character alphanumeric Unique Entity Identifier (UEI) code took its place. The DUNS number has been entirely removed from federal contracting, and in all places that the DUNS number was previously used, the UEI should take its place.

This has had ripple effects throughout the government contracting world, as now websites like FPDS.gov and GSA eLibrary use SAM’s UEI as well. Contractors already in SAM.gov were automatically assigned this new UEI, while contractors registering for the first time in SAM.gov are assigned one as part of the process after their entity validation, which we will touch on in a moment. The switch to an internal UEI means that contractors no longer need to go to a third-party services to verify their entity.

SAM.gov Entity Validation

Due to the change from DUNS Number to UEI, SAM has established a new form of entity validation in SAM.gov to take care of this process. This means that SAM needs to verify information such as your legal business name, physical address, state, and date of incorporation. The next time you login to SAM.gov, you may have to validate your entity to prove that your entity’s information is correct and current. Once your entity is validated, you will not need to validate it again unless the information changes, such as if your business moves.

As part of the SAM entity registration or renewal process, entity validation is one of the first steps. SAM will ask you to type in some information, including your legal business name and physical address. After you type in this information, the system will search in a database for matches of your company. If there are no matches, or only partial matches such as correct business name but incorrect address, you will need to provide acceptable documentation that affirms the name and address of your company. Once you’ve submitted this documentation, you will need to wait for the documentation to be reviewed. You must be very careful and ensure that your information matches exactly what is on the document you are providing, otherwise your entity will not be validated. Make sure you are following these tips if you want the entity validation process to be as expedient as possible.

Entity Validation Delays

Even if you provided impeccable information and documentation however, there is still no guarantee as to how long it will take for your entity to be validated. Entity validation has been taking anywhere from a few days to over a month under this new process, and in some cases longer. There have been some significant delays, so we suggest you start as early as possible. In fact, the Department of Defense (DOD) had to grant an exception for contractors who can prove they have initiated the entity validation process in SAM.gov that lasted from mid-September until October 31, 2022.

During the entity validation process, your entity registration is stuck in a bit of a limbo, so make sure that if you haven’t validated your entity since the change to UEI, you are starting to renew your SAM registration at least a month before it expires in case you have to validate your entity. That being said, if you do not need to renew or update your SAM registration, it is recommended to wait until you need to, if possible, as waiting times will likely be shorter in the future.

Once you’ve submitted your entity validation, you can check on its status by returning to your workspace in SAM.gov. When your entity is validated, you will receive an email. Then you can begin registering, renewing, or getting your Unique Entity ID.

Change in “Entity Administrator” Role Requirements

Each entity in SAM.gov has specific roles on the site. Having a role associated with a company is what allows individuals to do things like edit and renew the entity’s SAM registration or complete entity reporting. A login.gov account alone will not allow you access to your company’s SAM registration, you need to be assigned a role for the entity in SAM.gov as well.

One of these roles is the “Entity Administrator.” This individual has the power to edit and renew the entity’s registration like other roles, but it can also importantly assign or grant roles to other individuals within the entity. SAM used to allow third party individuals to become entity administrators, but decided to clamp down on this recently, sending a notice in August 2022.

Third party individuals who were listed as Entity Administrators will be reassigned to Data Entry roles, which will continue to allow them to create and manage entity registrations but not grant or assign roles for the entity. SAM has not set an official date for when third parties will no longer be eligible as entity administrators, or when third party entity administrators will be transitioned to data entry roles.

Changes to “Followed Records” in SAM

If you are an individual who “follows records” in SAM, there have been some improvements both aesthetically and functionally. If you are tracking an item, such as an entity, you will know notice that SAM provides:

• Prominent display of the record title and record type
• Display of important record data for each followed item reducing the need to open records 
• “Active” & “Inactive” record indicators 
• Additional sort and filter options
• Functionality to unfollow/update email frequency for multiple records at once
• Ability to view up to 100 records on a single page

These changes make it easier to track records in SAM than previously and provide a great way to keep track of changes, whether you’re keeping tabs on a competitor’s SAM registration or making sure you have the latest Wage Determinations.

Keeping Up with SAM Registration and Renewal

It’s important to note that despite all these changes, most of SAM remains the same. You still need to make sure you are on top of renewing your registration annually to avoid becoming inactive and jeopardizing your ability to receive contracting opportunities. You also want to make sure that you are accepting any applicable clauses and updating information as changes occur to your company. If you have any questions about how to renew your SAM registration or are experiencing difficulties in the entity validation process, feel free to reach out to Winvale and we would be happy to provide our expertise on the subject.