Fom USAID on December 14, 2022
In April 2022, the new SAM Unique Entity Identifier (UEI) replaced the DUNS number as the official government-wide identifier used for federal awards. USAID has been actively engaging with the General Services Administration (GSA) team to ensure that our partners are able to get meet the new registration requirements.
Highlighted below are actions that have been taken over the last six months to assist USAID staff and new and existing partners to overcome challenges with SAM registration:
- Developed escalation procedures for urgent registrations: We worked with GSA to develop an escalation process for Agreement and Contracting Officers (AOs/COs) and Agreement and Contracting Officer Representatives (AORs/CORs) to prioritize the resolution of urgent, time-critical registrations, and reduce the backlog of entity validations.
- Updated guidance for existing exceptions: We revised ADS 303maz to provide more detailed guidance on available exceptions related to UEIs and SAM registration for assistance awards.
- Issued new guidance to further address SAM registration difficulties:
- Acquisition exception. M/OAA obtained concurrence from the Civilian Agency Acquisition Council for a temporary exception regarding UEI/SAM registration for acquisition instruments. This exception allows a CO to issue a contract to an entity that can prove it has initiated the SAM registration process, but is not yet actively registered at the time of offer submission, when there are urgent circumstances requiring the award of the contract to meet the agency’s needs. AAPD 22-03 provides more details and instructions to COs.
- Assistance exception. M/OAA issued guidance under AAPD 22-04 in recognition of the extreme delays that entities currently face in obtaining a UEI and registering in SAM. This AAPD supplements the guidance in ADS 303maz and contains language for a special award condition that provides explicit instructions to the recipient regarding USAID’s expectations for UEI and SAM registration.
- Participation in an inter-agency working group: (Including the Department of State, the Development Finance Corporation, and EXIM) we are engaging with the Office of Management and Budget and GSA to seek additional flexibilities related to NCAGE codes (a prerequisite for SAM registration), UEIs, and SAM registration for assistance awards. We anticipate a solution to NCAGE requirements coming soon, and have already successfully negotiated a temporary waiver for assistance awards in Kosovo due to the unique circumstances impacting entities in the country and their inability to obtain NCAGE codes.
- Highlighted SAM-related flexibilities to the A&A workforce: We clarified to USAID staff that SAM registration is not required by an applicant prior to the submission of a concept note. M/OAA also provided a reminder of existing exceptions to SAM registration, such as an option for acquisition instruments for work in locations designated “danger pay” posts by the Department of State and for contract actions at or below $30,000 awarded to foreign vendors for work performed outside the United States, if it is impractical to obtain SAM registration. For additional details on existing exceptions, see ADS 302mbj for acquisition and ADS 303maz for assistance.
- Industry outreach: Through Business Forecast calls, social media engagement, partner association outreach, webinars, and blogs, we continue to communicate with partners on how to register on SAM.gov, including answering questions about when a partner must be registered in order to apply for funding.