Thank you Susan. Was the requirement per the prime award, or your institutional requirement?
From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG>
On Behalf Of Cao, Susan
Sent: Tuesday, December 8, 2020 2:55 PM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: Re: [RESADM-L] Does a subrecipient need to be registered on sam.gov?
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We had a foreign sub-recipient on a USDA-NIFA grant as well as two non-profits that had never received federal funding before.
ALL of them had to register in SAM.gov before funding could be awarded.
Susan Cao
Project Specialist – Large Grant Development Office
CAHNRS Office of Research
Washington State University
Pullman, WA 99164-6240
Phone: 509-335-6881
Email:
xxxxxx@wsu.edu
Physical Location: Working remotely due to Covid
From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG>
On Behalf Of MacCue, Carrie
Sent: Tuesday, December 8, 2020 11:37 AM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: Re: [RESADM-L] Does a subrecipient need to be registered on sam.gov?
Greetings Listserv,
I just wanted to circle back to this question. I appreciate the responses below, but wanted to see if anyone else had input. I’m working with foreign subrecipients (on an NIH prime) right now and they are not registered in SAM.gov. Can
anyone point to solid guidance on this matter? The NIH GPS is unclear:
:Additionally, all applicant organizations must register in the System for Award Management (SAM) and maintain the registration with current information at all times during which such organizations have an application under consideration
for funding by NIH and, if an award is made, until a final financial report is submitted or the final payment is received, whichever is later. SAM is the primary registrant database for the Federal government and is the repository into which an entity must
provide information required for the conduct of business as a recipient. Effective January 1, 2020, SAM will become the central repository for common government-wide certifications and representations required of NIH applicants and recipients. Additional information
about registration procedures may be found at the SAM internet site at
https://www.sam.gov/SAM/.
If an award is granted, the recipient organization must notify potential subrecipients that no organization may receive a subaward under the grant unless the organization has provided its
DUNS number to the recipient organization.”
Thanks so much,
Carrie
From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG>
On Behalf Of Samantha Levin
Sent: Wednesday, October 30, 2019 10:23 AM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: Re: [RESADM-L] Does a subrecipient need to be registered on sam.gov?
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Hi Susan & Julie,
There is indeed some confusion. As Julie points out 2 CFR 25.110 appears to include both subs and primes for SAM.gov registration. But the language in Appendix A, the part that ends up in our
award agreements, only specifies that prime recipients are required to be registered in SAM.gov. 2 CFR 25.100+ concerns SAM.gov
and DUNS. Appendix A does say that both the prime and any subs must have a DUNS.
I’ve worked with over 30 subrecipients, successfully closed out prime awards, and none of them were registered in SAM.gov. (SAM.gov is only available in English and quite burdensome for non-English
speakers (it’s burdensome even for English speakers). It’s a major deterrent from organizations registering “just in case.”) Subs were still required to have a DUNS and to be able to “pass” a SAM.gov and OFAC/SDN search though (nothing showing up is “passing”).
If the subrecipient anticipates becoming a prime recipient, or continuing to receive USG funding in any form, it is in their best interest to register with SAM.gov. If they’re receiving a substantial
sum of money annually, over the audit threshold, then they really need to register in SAM.gov.
Thank you,
Sam
Samantha Levin
Grants & Contracts Manager
American College of Surgeons
T:
+1 312.202.5651
|
xxxxxx@facs.org
From: Renkas, Julie Ohlandt [mailto:xxxxxx@COFC.EDU]
Sent: Tuesday, October 29, 2019 10:40 AM
Subject: Re: Does a subrecipient need to be registered on sam.gov?
Generally, yes, unless an exemption under in 2 CFR 25.110 is identified:
https://www.ecfr.gov/cgi-bin/text-idx?SID=c1b421eea138bcc26dcc06c4d48e9bcc&mc=true&node=se2.1.25_1110&rgn=div8
Best,
Julie
From: Research Administration List [mailto:xxxxxx@LISTS.HEALTHRESEARCH.ORG]
On Behalf Of Susan Brau
Sent: Tuesday, October 29, 2019 11:20 AM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: [RESADM-L] Does a subrecipient need to be registered on sam.gov?
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attachments unless you recognize the sender and know the content is safe.
Good morning,
Quick question: does a grant subrecipient need to be registered on sam.gov to receive subrecipient funding? I always assumed yes, but now I cannot find that in any documentation.
Please advise!
Thank you,
Sue
Susan Brau
Director of Finance
200 Harvard Mill Square, Suite 210
Wakefield, MA 01880
Direct line: 781.683.4268
T: 781.245.2212 x268| F: 781.245.5212
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