Hi All –

I was under the impression that Although 2 CFR 25 requires that all entities applying for or receiving federal awards, including subrecipients of federal awards, must register in SAM, there are conditions under which a federal agency may exempt a foreign entity from this requirement.

As a rule of thumb, even if they don’t need to register in SAM, I actually have them complete the old school debarment form – not sure if there is a better process.

Meredith Albuquerque

Associate Director of Grant Compliance

Southern New Hampshire University

2500 North River Road

Manchester, NH 03106

(603)644-3129

https://alumni.snhu.edu/operations/grant-resources

cid:image001.png@01CF7606.AA1073C0

From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On Behalf Of MacCue, Carrie
Sent: Tuesday, December 8, 2020 3:58 PM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: Re: [RESADM-L] Does a subrecipient need to be registered on sam.gov?

Thank you, Sara. I did see this, but its not clear about Subrecipients. It does say subcontracts are not required to register. I’m stuck in the weeds here…

5. APPLICABILITY TO SUBCONTRACTORS

Comment: One respondent recommended that the rule clarify that the prime and any key subcontractors are required to be registered upon proposal submission, but that lesser subcontractors or consultants are only required to be registered prior to receipt of a subaward.

Response: Subcontractors or consultants to prime contractors are not required to be registered in SAM.

From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On Behalf Of Sara Santos
Sent: Tuesday, December 8, 2020 3:41 PM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: Re: [RESADM-L] Does a subrecipient need to be registered on sam.gov?

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Hi Carrie,

The Federal Register (FAR 4.1102) mandates that business acquire a System for Award Management (SAM) registration for federal contracting and for nonprofits to receive grants. Here is the reference: FAR Acquisitions SAMS Registration

Best, Sara

…………………..

Sara Santos

Pre-Award Research Administrator

From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On Behalf Of MacCue, Carrie
Sent: Tuesday, December 08, 2020 3:29 PM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: Re: [RESADM-L] Does a subrecipient need to be registered on sam.gov?

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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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

xxxxxx@cast.org

CAST | Until learning has no limits

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