Member Article

The System for Award Management (SAM.gov) is an official website of the U.S. government that federal contractors must use to register to do business with the federal government, including updating and maintaining their entity registration and including representations and certifications regarding size, location, and socio-economic status.

In order to maintain and update an entity’s SAM.gov registration, federal contractors assign Entity Administrator, Data Entry, or Viewer to individuals. The Entity Administrator role is the top level role and has overall control of an entity’s registration in SAM.gov, including the ability to:

• Register a non-federal entity.
• View active and expired registrations.
• Update active and expired registrations.
• Deactivate active registrations.
• View draft, work in progress, and submitted registrations.
• Update draft and work in progress registrations.
• Delete draft and work in progress registrations.
• View pending hierarchy registration requests.
• Approve or reject pending hierarchy registration requests.
• Administer the Administrator, Data Entry, and Viewer roles for entities. There can be more than one Entity Administrator for an entity.

Currently, and historically, federal contractors have been able to appoint third parties, such as compliance consultants or service providers, to serve as Entity Administrators for their SAM.gov registration and to manage their SAM.gov registration. Starting on March 3, 2023, that will no longer be available.

The federal government has announced that:

Beginning March 3, 2023, Entity Administrator roles can only be held by employees, officers, or board members of the organization…

Effective March 3, 2023, when you register an entity or update an entity registration, you must attest to your affiliation with the entity. If you are not an employee, officer, or board member of the entity, you will no longer be able to hold the Entity Administrator role. Instead, you will be given the Data Entry role. With that role, you can continue to register new entities, manage updates, and renew entity registrations, but you can’t manage user roles.

Entities assigning Entity Administrator roles using an Entity Administrator Appointment Letter, (sometimes known as the notarized letter process) will no longer be able to assign the Entity Administrator role to a non-employee. 

Federal contractors who have someone who is not an employee, an officer, or a board member assigned the role of Entity Administrator in SAM.gov will eventually have to update their role to Data Entry and identify an employee, an officer, or a board member to take on that role. Federal contractors should also consider identifying personnel who can serve as backup Entity Administrators, to ensure there is no disruption in their SAM.gov registration in the event of a personnel change.

This article summarizes aspects of the law and does not constitute legal advice. For legal advice for ‎your situation, you should contact an attorney.

 

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