Nonprofits that receive CSLFRF funds from the local government are required to register on the System for Award Management. Does this require a full SAM registration for the nonprofit, or is having an active Unique Entity Identifier on SAM sufficient?

The U.S. Department of the Treasury ("Treasury") Coronavirus State and Local State Fiscal Recovery Funds ("CSLFRF") Compliance and Reporting Guidance specifies that CSLFRF recipients, together with any subrecipient(s) administering a program on their behalf, “will need to maintain procedures for obtaining information evidencing a given beneficiary, subrecipient, or contractor’s eligibility, including a valid SAM.gov registration.”[1] Recipients are responsible for subrecipients’ compliance with registering and maintaining an updated profile on SAM.gov.[2]

The System for Award Management (“SAM”) database at SAM.gov is the official government-wide database on which participants must register prior to doing business with the U.S. government.[3] All recipients of federal financial assistance must register on SAM.gov and renew their SAM registration annually to maintain an active status in order to be eligible to receive federal financial assistance. Registration on SAM.gov is a four-part process which includes:

• Obtaining a unique entity identifier from Dun & Bradstreet (DUNS number).
• Preparing data to be included with the entity’s registration.
• Obtaining a login.gov account.
• Submitting data and finishing the registration process.[4]

A non-profit entity receiving CSLFRF funds from a local government will be required to maintain a valid SAM registration. While obtaining a Unique Entity Identifier from Dun & Bradstreet is the first step in the registration process, Treasury’s Compliance and Reporting Guidance mandates full SAM registration for federal assistance. Registration is free of charge. If a nonprofit does not have an active registration, the organization may register on SAM.gov to begin the entity registration or renewal process, which may take up to ten business days. Delay in registering on SAM could impact timely payment of funds.