Photo of Peter J. EyrePhoto of Laura J. Mitchell Baker

The General Services Administration’s (GSA) System for Award Management (SAM) announced its role in an ongoing Inspector General Investigation into alleged, third party fraudulent activity in SAM.

GSA suspects that the alleged fraudulent activity impacted only a limited number of entities.  GSA has since notified the affected entities, and deactivated their SAM registrations.  GSA also required these entities to validate and confirm their registration and bank account information in SAM before reactivating their SAM registrations.

As a result, GSA is taking additional proactive steps to address the issue and prevent future fraudulent activity, including implementing the following new requirements for SAM registration.

  • As of March 22, 2018, new entities are now required to submit an original, signed, and notarized letter, identifying the authorized Entity Administrator for the entity before a new SAM registration is activated.
  • Beginning April 27, 2018, existing entities will be required to submit this notarized letter to confirm the authorized Entity Administrator for the entity before the current SAM registration is updated or renewed.

To assist new and existing entities with these new requirements, GSA’s Federal Service Desk provides a list of detailed requirements for the notarized letter:

  • The letter must be printed on the entity’s letterhead, contain the signature of someone with signature authority (e., the president, CEO, or other authorized representative), and notarized;
  • The letter must also identify the Entity Administrator; and
  • Once signed and notarized, the original letter must be mailed to the Federal Service Desk.

New and existing entities should review these requirements to ensure new registrations or renewals are timely completed.  These additional steps are likely to increase the time required to complete the SAM registration and renewal processes.  Contractors are well advised to plan ahead and start early.  And as GSA advises, contractors should routinely review their registration and bank information in SAM for accuracy.

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Photo of Peter J. Eyre Peter J. Eyre

Peter J. Eyre is a partner and co-chair of Crowell & Moring’s Government Contracts Group. He is also a member of the firm’s Management Board. Peter was named to BTI Consulting Group’s list of “Client Service All-Stars” in 2016, 2017, and 2019 and…

Peter J. Eyre is a partner and co-chair of Crowell & Moring’s Government Contracts Group. He is also a member of the firm’s Management Board. Peter was named to BTI Consulting Group’s list of “Client Service All-Stars” in 2016, 2017, and 2019 and has been named an Acritas Star, Acritas Stars Independently Rated Lawyers (2016, 2017, 2019). He is nationally ranked by Chambers USA in Government Contracts since 2014, and by Super Lawyers since 2017.

Photo of Laura J. Mitchell Baker Laura J. Mitchell Baker

Laura J. Mitchell Baker is a counsel with Crowell & Moring’s Government Contracts Group in the firm’s Washington, D.C. office.

Laura represents government contractors in litigation and administrative matters, including contract disputes with state and federal entities, suspension and debarment proceedings, mandatory disclosures…

Laura J. Mitchell Baker is a counsel with Crowell & Moring’s Government Contracts Group in the firm’s Washington, D.C. office.

Laura represents government contractors in litigation and administrative matters, including contract disputes with state and federal entities, suspension and debarment proceedings, mandatory disclosures to the government, prime-sub disputes, and False Claims Act investigations. Her practice also includes counseling on federal, state, and local government contracts, government contracts due diligence, and regulatory and compliance matters, as well as conducting internal investigations.