Important June Update Notices From GSA on Initially Establishing and Maintaining Government Contracting Registrations

GSA. GOV SAM Update

GSA has taken action to address fraudulent activity in the System for Award Management (SAM). The measures GSA already put in place to help prevent improper activity in SAM include masking specific data elements in the entity registration even for authorized entity users; requiring “parent” approval of new registrations for their “child” entities; and requiring the formal appointment of the Entity Administrator by original, signed notarized letter.

Additional enhanced controls will be deployed at the end of June. These controls include implementing multi-factor authentication using Login.gov and notifying Entity Administrators when there is a change in the entity’s bank account information. As a result of these and other measures, GSA is modifying the current notarized letter review process in two phases.

NOTARIZED LETTER PROCESS CHANGES

How is the notarized letter review process changing on June 11, 2018?

• Effective June 11, 2018, 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 no longer need to have an approved Entity Administrator notarized letter on file before their registration is activated.
  • Hint: This applies to you if your SAM.gov Purpose of Registration is Federal Assistance only. Check SAM.gov to find your Purpose of Registration.
• Federal Assistance entities still must mail the original, signed copy of the notarized letter to the Federal Service Desk. Failure to do so within 30 days of activation may result in the registration no longer being active.

How is the notarized letter review process changing on June 29, 2018?

• Effective June 29, 2018, all non-Federal entities who create or update their registration in SAM.gov will no longerneed to have an approved Entity Administrator notarized letter on file before their registration is activated.
  • Hint: This applies to you if your SAM.gov Purpose of Registration is either Federal Assistance or All Awards. Check SAM.gov to find your Purpose of Registration.
• All non-Federal entities still must mail the original, signed copy of the notarized letter to the Federal Service Desk. Failure to do so within 30 days of activation may result in the registration no longer being active.

Where can I find the notarized letter templates?

• Read the instructions for domestic entities or instructions for international entities posted at the Federal Service Desk.

Does the notarized letter requirement apply to U.S. Federal Government entities registering in SAM?

• No.

NEW LOGIN PROCESS FOR SAM.GOV COMING JUNE 29, 2018!

What is the new login process for SAM.gov?

• Effective June 29, 2018, when you go to SAM.gov and log in, you will be asked to create a Login.gov user account. Your current SAM.gov username and password will no longer work.

What is the most important thing I need to do before June 29th?

• Make sure you know the email address associated with your current SAM.gov user account.

Why do I need my current SAM.gov user account email address?

• Using the same email address allows SAM.gov to automatically migrate your roles. If a different email address is provided, your roles will need to be reassigned. This could cause delays updating your existing registrations.

How do I find the email address for my SAM.gov user account?

• If you don’t know which email is associated with your SAM.gov user account, take action now. Go to www.SAM.gov → My SAM → My Account Settings → Edit User Information. As of June 29, 2018, your current username and password won’t work, so take steps now to confirm your email!

What do I need to create my Login.gov user account?

• You will need to:
  1. know the email address associated with your SAM.gov username and password
  2. have access to that email to receive a confirmation email from Login.gov, and
  3. have a working phone (cell phone or landline) to receive a security code from Login.gov.

Why is SAM.gov making these user account changes on June 29, 2018?

• To further increase security and deter fraud, SAM.gov is partnering with Login.gov to implement multi-factor authentication for registered SAM.gov users.

Will this change impact public users who do not log in to SAM.gov?

• No. There is no change for users who search and view public data on SAM.gov without logging in to the system.

Will I be able to get help for this new login process?

• Yes. SAM will post additional instructions, the Federal Service Desk will be available to support, and you can go to Login.gov to learn more about creating an account.

BACKGROUND

GSA's System for Award Management (SAM) continues to support an active investigation by the GSA Office of Inspector General (OIG) into alleged, third-party fraudulent activity in SAM. Only a limited number of entities registered in SAM were suspected of being impacted by this alleged fraudulent activity. In March 2018, GSA took steps to address this issue and notified affected entities. GSA continues to work with the OIG and law enforcement agencies to take additional action, as appropriate.

What has GSA been doing to address the problem?

GSA took a number of proactive steps to address this issue, including system modifications, to prevent improper activity going forward. In addition, GSA expired, then deactivated any entity registrations that appeared to have been affected. These entities were advised to validate their registration information in SAM, particularly their financial information and points of contact, before reactivating the entity registrations. Further, GSA has begun implementing additional reviews during the registration process to prevent future issues.

What interim changes were made to the SAM registration process?

These proactive steps include requiring submission of an original, signed notarized letter identifying the authorized Entity Administrator for the entity associated with the Data Universal Numbering System (DUNS) number. GSA posted instructions for domestic entities and instructions for international entities for easy reference. This requirement went into effect on March 22, 2018, for new entities registering in SAM and went into effect on April 27, 2018, for existing registrations being updated or renewed in SAM. Changes are coming to this process on June 11, 2018, for Federal Assistance only entities and on June 29, 2018, for all entities.

Who was impacted?

Entities with registrations that appeared to be impacted were notified. Instructions were provided explaining how to validate registration information and how to reactivate the registration. In addition, entities whose bank account information for Electronic Fund Transfer (EFT) changed within the 12 months prior to March 2018 were notified. Although not associated with suspicious activity, these entities are required to validate their registration information, particularly their EFT information.

What is an entity?

In SAM, you, your company, business, or organization is referred to as an “entity.” Individuals register themselves or their entity to do business with the U.S. Federal Government by completing the registration process in SAM.

What should entities registered in SAM do to protect themselves and confirm that their bank account information has not been changed?

Entities registered in SAM are advised to log into SAM and review their registration information, particularly their bank account information for Electronic Funds Transfer (EFT) on the financial information page. Contact the supporting Federal Service Desk at www.fsd.gov, or by telephone at 866-606-8220 (toll free) or 334-206-7828 (internationally) Monday through Friday from 8 a.m. to 8 p.m. (ET), for FREE assistance. Entities are responsible for ensuring that their information is current and correct in SAM in accordance with paragraph (b) of Federal Acquisition Regulation (FAR) clause 52.232-33 or Title 2 of the Code of Federal Regulations Part 25 (2 CFR § 25.310 and Appendix A), as applicable, and should routinely review such information for accuracy.

Who should entities contact if they find that payments due them from Federal agencies have been paid to a bank account that other than their own?

If an entity suspects a payment due them from a Federal agency was paid to a bank account other than their own, they should contact the Federal Service Desk at www.fsd.gov, or by telephone at 866-606-8220 (toll free) or 334-206-7828(internationally), Monday through Friday from 8 a.m. to 8 p.m. (ET), for FREE assistance.

Where can an international entity find information about the notarized letter process?

Entities not located in the U.S. or its outlying areas should read the international entity instructions posted at the Federal Service Desk that outline procedures and provide links to letter templates. If they have additional questions, international entities should contact the Federal Service Desk at www.fsd.gov, or by telephone at 866-606-8220 (toll free) or 334-206-7828 (internationally), Monday through Friday from 8 a.m. to 8 p.m. (ET), for FREE assistance.

GSA’s Office of the Inspector General (OIG) is actively investigating alleged, third party fraudulent activity in the System for Award Management (SAM).  At this time, only a limited number of entities registered in SAM are suspected of being impacted by this fraudulent activity. GSA is in the process of notifying these affected entities.

IMPORTANT NOTE:  In a proactive step to address this issue, GSA is now requiring an original, signed notarized letter identifying the authorized Entity Administrator for the entity (company) associated with the DUNS number before a new SAM.gov entity registration will be activated. GSA has very specific requirements for this notarized letter—click here for Federal Service Desk (FSD) guidelines.  A template has been developed by Procurement Technical Assistance Center (PTAC) experts that can serve as the starting point for this document.  It must be completed with the specified information, printed on company letterhead, notarized, and mailed to the Federal Service Desk at the address indicated. Download Template here.

Who is impacted? Entities who may have been impacted are those whose financial information has changed within the last year. GSA began notifying affected entities on March 22, 2018.

All entities registered in SAM are advised to log into SAM and review their registration information, particularly their financial (bank account) information. GSA reminds everyone that entities are responsible for ensuring that their information is current and correct in SAM.

Any entity finding that a payment due to them from a federal agency has been paid to a bank account other than their own should contact their Federal agency awarding official.

How is GSA addressing this situation?  In addition to the above, GSA has expired – then deactivated – any entity registrations that appeared to have been affected. These entities are being advised to validate their registration information in SAM, particularly their financial information and points of contact. Further, GSA has begun implementing additional reviews during the registration process to prevent more issues.

Full information on the situation can be found on GSA’s website (click here).

_____________________________________________________________________

FURTHER GUIDANCE FROM SMALL TO FEDS:

You have worked hard establishing your small business in the commercial market; or you have succeeded in your profession working for large enterprises. You have established yourself and you are recognized as a success by your superiors, your peers and your subordinates. Someone or something one day attracts your attention with the suggestion that the federal government may be in the market for your skills, products or services. This article will address the path to expanding your existing business or initially undertaking a business involving federal government contracts.


 GETTING STARTED

The best way to explore federal government contracting possibilities is to expand your business plan to include a sector for that type of business or develop your start up plan including a federal government business sector. Doing business with the Federal Government is not "Rocket Science" but it is different. It embodies a set of regulations entitled, "The Federal Acquisition Regulation" or FAR, which contain the rules by which the government and industry abide in contracting for supplies and services. The FAR had its genesis during World War II and has evolved since that time to control and regulate the ever-expanding amounts of goods and services which the federal government buys.

The following are the most important "Mechanical Steps" necessary in positioning your business to begin selling to the federal government. They are listed in the necessary sequence for becoming a supplier entity in the government system. A link to appropriate web sites is provided at each step.

A. Dunn &Bradstreet (D&B) Number Go to Small Business Tab At:

http://www.dnb.com/us/

If you do not have one a D and B Number is necessary before you can complete a Registration (CCR) which is required for all companies who aspire to sell to the federal government. A D and B Number is also required for your Small Disadvantaged Business (SDB) application if you intend to pursue minority- owned business certification. If you are not already incorporated you may wish to incorporate before you set up your D and B number. Incorporation is fairly inexpensive these days and can be done via the WEB for either a non-profit or a for-profit business. Try search mechanisms, such as "Incorporate.com", or "Incorporate Now". It is best to do a check with the Better Business Bureau before using the results. Establishing your D and B is free.

B. For Central Contractor Registration:

https://www.sam.gov/portal/SAM/##11#1

C. For application in the SBA Small, Disadvantaged Business (SDB) Program:

http://sba8a.symplicity.com/applicants/guide

If you qualify as a minority, follow the directions closely. Note there is a preview section which will acquaint you with the application and the types of information that will be necessary when you start the process.

D. For Historically Under-Utilized Business (HUB) Zone Information:

https://www.sba.gov/contracting/government-contracting-programs/hubzone-program/hubzone-maps

Note that Hub Zone qualification is based on where the business is located and where the personnel in the business reside as well.

E. For Searches on Federal Buys:

http://www.fedbizopps.gov/

FEDBIZOPS is the gateway for all federal business. The search tool there is a very powerful engine with many filters that are useful. It is well worth the time to learn the filters. Every federal agency is required by regulation to advertise there and you will be amazed at the products and services the federal government buys.

F. For an example of a small business capability statement check the following web site:

http://www.smalltofeds.com/2011/05/your-capability-statement-cape-for.html

A capability statement is always a good idea for marketing. The link above as an example. It was found on the web in the public domain Note that the site is a SDB. Later you will get into proposal preparation and the regulations governing the types of grants and contracts, as well as billing the government for your work and other factors.

G. Questions for you:

Are you planning to produce a deliverable, distinct, end product such as software, hardware, a commodity, a report, a conference, a survey or a study, sell it to meet the government's statement of work and bill for the end product when delivered?

OR

Are you planning to price your services at an hourly rate, sell them by labor categories with professional job descriptions to perform the government's statement of work and bill by the hour for labor and at cost for material and travel?

Answers to the above questions are key factors in how you set up your business and price your work in proposals to federal agencies. The answer to the above questions is "Yes" in both cases for some businesses. Some small businesses sell their product commercially, but contract for product implementation and support on a service contract basis.
The next topic in this series of articles will deal with avenues for marketing a small small business in the federal government environment.

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