SAM Notarized letter requirement – Q&A from GSA

Latest Information on SAM registration and renewal requirements

(last update June 1, 2018)
In the wake of the System for Award Management data breach in late March, APTAC has been in close communication with GSA officials in an effort to ensure that information on how to best meet new SAM registration/update requirements gets out to the PTACs and their small business clients as quickly as possible.  GSA is responding to questions submitted by APTAC on an ongoing basis.  Please see this important information below, which will be updated as new responses are received. Remember, find your local PTAC counselor (click here) for help with this and other contracting issues.

GSA recommends the following to entities submitting notarized letters: 

1. Use one of the templates provided in the FAQs.  Review the applicable instructions for domestic entities or international entities to ensure you select the appropriate template.

2.Complete all sections of the templateto avoid these main causes of rejection

  • Failure to include a statement clarifying your account administration preference.  The template directs you to select one of two choices for who can administer your account, either self administration confirmation or third party agent designation. Your letter must indicate one or the other.
  • Information not matching. Double check that the appointed Entity Administrator’s email address and phone number, as well as the entity physical address, match the information contained in the SAM registration. Take the extra time to ensure all information is accurate and complete or you will be required to submit another hard copy notarized letter.
  • Missing digits in the DUNS Number. Include all nine digits of your DUNS Number. Do not ignore leading and ending zeros.  Double check the DUNS Number for accuracy against your SAM registration.

Notarization Requirements
The type of stamp or seal required on notarized documents varies from state to state.  CLICK HERE for a spreadsheet with each state’s requirements. A graphic with this information is also available (click here to view graphic).

Questions regarding the submission of notarized letters:

Q: When should the notarized letter be sent – simultaneously with electronic submittal or after CAGE code is received?
A: Entities can submit at any time – they do not need to wait to clear CAGE.

Q:  Should entities expect an email or a letter that confirms receipt?
A:  There is no email to confirm receipt of the letter. Once the letter is received, it is opened and sent forward for processing.  An email is sent once the letter is processed (an FSD ticket is created when the letter has been reviewed). The email will contain information about whether the letter is accepted or rejected. If rejected, the letter will include the reason for rejection and instructions to resolve the issue.

Q:  Should entities mail their letter via Certified Mail, Return Receipt Requested?  
A:  Incoming letters are handled in the order received.  Entities may send the letter using certified mail to get the return receipt or use an express mail service if they wish to track the physical receipt of the letter. (Since there is no email confirmation of receipt, you may indeed want to send it return receipt requested, just so that you can be confident that your letter was received.)

Q: How will entities be notified once their letter is accepted or rejected?  
A:  The entity administrator will receive an email after the review is completed.  The email will contain information about whether the letter is accepted or rejected. If rejected, the letter will include the reason for rejection and instructions to resolve the issue.

Q:  What is the estimated processing time?
A:  The processing time is dependent on the volume of letters received, whether the letter is accepted/rejected, and the additional impact of including existing entities who are renewing or updating their registrations.  As the data normalizes, GSA will provide updates to APTAC.

Q:  While waiting on a response, should entities log-in to SAM to check the status  or update?  
A:  The last step of the notarized letter review process is for the Federal Service Desk representative to indicate in SAM the approved letter is on file. If the registration is in submitted status and has passed all other external validations, it should be active within the hour.SAM will also send an acknowledgement when the registration is active.  Entities may use the Check Status tab in the SAM main navigation bar to see where their registration is in the review process.

Q: Due to the long wait times being experienced by callers to the Federal Service Desk, is there a particular time of day and/or day of the week that entities should call or use live chat?
A: Historically call volume increases during the middle of the day.  The FSD hours are Monday through Friday 8:00 am to 8:00 pm ET.  (In other words, early or late in the day may be less busy than in the middle of the day).

In the event that an entity is facing an imminent contract award while awaiting approval of their notarized letter, is there a way to:

Q: Receive a provisional approval or request expedited processing/approval of their notarized letter?  
A:  All entities must complete the process in its entirety.  Entities are unable to request an expedited review of their notarized letters.  When the Government determines a need, the Government contracting officer may submit a request for escalation to their designated IAE Change Control Board (CCB) member, who will be able to submit the request to GSA for escalation. The contracting officers should go through their chain of command to determine the CCB reps.  They are often the administrators of FBO and FPDS roles in their agencies.

Q:  Request communication from GSA or FSD to the contracting officer, explaining the entity’s status?  
A:  The contracting officer can track the status of the registration through the status tracker on SAM.  If the registrant has cleared the CAGE review process and the notarized letter is approved, the registration will be activated.   If a notarized letter is received and approved prior to completion of the CAGE approval, the file will be flagged so the registration can move forward to activation immediately after CAGE approval.

Q:  Otherwise protect the entity awaiting the processing of their letter from contract disqualification?  
A:  Entities are required to be registered in SAM prior to award in accordance with FAR Subpart 4.11 requirements. The notarized letter is now part of the registration process. GSA cannot exempt entities from registration.

GSA is working to develop alternatives to the requirement for the original signed, notarized letter and will post updates to and as they become available. No timeline has been provided.