Navigating the notarized letter requirement
***UPDATE: Please click here to view changes in the notarized letter requirement as of 6/11/2018. Even with the changes, many of the tips below remain useful.
In the wake of the System for Award Management (SAM) data breach in late March, GSA has instituted a requirement for every new and renewing registrant to submit a notarized letter appointing an “Entity Administrator” – the person authorized to make changes to the registrants SAM profile, particularly with regard to banking information. As a result, the agency has been receiving tens of thousands of notarized letters, each of which must be reviewed to ensure validity and compliance. Despite best efforts, processing the letters has gotten backed-up, and some firms are experiencing delays in their registrations or renewals of weeks or even months.
APTAC has been in close communication with GSA officials to help ensure that information on how to best navigate the new requirements gets out to the small business contracting community. Please take advantage of the tips below, and see our full information page: SAM Notarized Letter Requirement – Q&A from GSA, which will continue to be updated as new information becomes available.
Give yourself plenty of lead time: Start your renewal process early, knowing that it may take several weeks for the Federal Service Desk (FSD) to approve your letter. You don’t want to risk being ineligible for a contract award because your SAM registration has expired.
Send your notarized letter immediately upon completing electronic submittal. There is no need to wait until your CAGE code is received; you want to get your notarized letter into the queue as quickly as possible.
Use a GSA template (click here) provided on the FSDs Frequently Asked Questions (FAQs). Note that there are separate templates for domestic versus international entities. Make sure that you use the appropriate one.
Complete ALL sections of the template to avoid the main causes of rejection:
- Failure to include a statement clarifying 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 of the notarized letter – resulting in additional delays.
- 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.
Make sure your notarized letter includes the appropriate stamp or seal. The type of stamp or seal required varies from state to state. Click here for a spreadsheet with each state’s requirements.
Send your notarized letter via Certified Mail with return receipt requested. FSD does not provide email confirmation that a notarized letter has been received. So if you want the peace of mind of knowing that your letter arrived safely, use certified mail with return receipt requested.
Check your status by logging into your SAM account. The last step of the notarized letter process is for the FSD to indicate in SAM that the notarized letter is on file. If the registration is in submitted status and has passed all other validations when letter is approved, the registration will become active, and SAM will send you a notification to that effect. You may also use the Check Status tab in the SAM main navigation bar to see where your registration is in the review process.
Avoid calling FSD mid-day if possible. FSD is experiencing a high volume of calls, and historically call volume increases during the middle of the day. If you want to decrease the likelihood of a long wait time, try to call early or late in the day. FSD hours are Monday through Friday, 8:00 am to 8:00 pm ET.
What if I have a contract pending? Only federal contracting officers may request expedited review of notarized letters. If your contracting officer determines it a government priority, he or she can go through their chain of command to submit a request for escalation to their designated IAE Change Control Board (CCB) member, who is often the administrator of FBO and FPDS roles in their agencies.
FAR Subpart 4.11 requires entities to be registered in SAM prior to contract award. The notarized letter is now part of the registration process, and no entity may be exempted from this requirement. It is only prudent to take every step within your power to maximize the likelihood that your registration or renewal can be accomplished with the minimum of delays.
GSA is working to develop alternatives to the requirement for the notarized letter, but no timeline has been released as to when that might occur. So stay informed, be proactive, and reach out to your PTAC if you have questions or need help.
Remember: There is NEVER a fee to register as a government contractor. Repeat – there is NEVER a fee to register as a government contractor. And PTACs are available with free and low-cost help available to get you through the process.
To receive assistance with any aspect of vendor registration with any government agency at no cost, please feel free to contact a PTAC near you.
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