It is my understanding only "prime" recipients of federal funds MUST register in Sam.gov. You may have an institutional policy that requires all your subrecipients to register in Sam.gov, but I don't think the federal government requires that of subrecipients. This is an excerpt from http://www.nsf.gov/pubs/policydocs/pappguide/nsf13001/gpg_1.jsp:
IN ADDITION, EACH PROPOSER ALSO MUST BE REGISTERED IN THE SAM DATABASE PRIOR TO SUBMISSION OF THE PROPOSAL. SUBAWARDEES NAMED IN THE PROPOSAL, HOWEVER, DO NOT NEED TO BE REGISTERED IN SAM.
This is an excerpt from the Sam.gov User Guide. "Entity" is defined as a "Prime" contractor, organizations, or individual applying for assistance awards.....
https://www.sam.gov/sam/transcript/SAM_User_Guide_v1.8.pdf
1.3
WHO SHOULD USE SAM ?
SAM IS USED BY ANYONE INTERESTED IN THE BUSINESS OF THE FEDERAL GOVERNMENT, INCLUDING:
ENTITIES (CONTRACTORS, FEDERAL ASSISTANCE RECIPIENTS, AND OTHER POTENTIAL AWARD RECIPIENTS) WHO NEED TO REGISTER TO DO BUSINESS WITH THE GOVERNMENT, LOOK FOR OPPORTUNITIES OR ASSISTANCE PROGRAMS, OR REPORT SUBCONTRACT INFORMATION;
GOVERNMENT CONTRACTING AND GRANTS OFFICIALS RESPONSIBLE FOR ACTIVITIES WITH CONTRACTS, GRANTS, PAST PERFORMANCE REPORTING AND SUSPENSION AND DEBARMENT ACTIVITIES;
PUBLIC USERS SEARCHING FOR GOVERNMENT BUSINESS INFORMATION.
*FOR THE PURPOSES OF THIS CAPABILITY AREA,
ENTITY REFERS TO PRIME CONTRACTORS, ORGANIZATIONS OR INDIVIDUALS APPLYING FOR ASSISTANCE AWARDS, THOSE RECEIVING LOANS, SOLE PROPRIETORS, CORPORATIONS, PARTNERSHIPS, AND ANY FEDERAL GOVERNMENT AGENCIES DESIRING TO DO BUSINESS WITH THE GOVERNMENT
Barbara O'Malley
Subaward Manager
Office of Research Administration
University of Maryland College Park
3112 Lee Building
College Park, MD 20742-5141
(301) 405-6276
xxxxxx@umd.edu
-----Original Message-----
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Forster, Marjorie
Sent: Tuesday, December 23, 2014 2:46 PM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] International Subcontract Requirements
A colleague who manages our subcontract port folio has asked that I pose the following question to this esteemed group.
US based subrecipients are required to have a DUNS number and register with CCR or now with SAM. My colleague's question is whether foreign/international subrecipients in addition to having a DUNS number are also required to register with CCR or SAM in order to receive federal funds? Many thanks.
Happy Holidays.
Marjorie Forster
Assistant Vice President, Research and
Global Health Initiatives
Office of Research and Development
University of Maryland Baltimore
620 West Lexington Street, Suite 400
Baltimore, MD 21201
410-706-6631
410-706-6630 (fax)
xxxxxx@umaryland.edu
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