Notice Number: NOT-OD-18-162
Release Date: March 29, 2018
National Institutes of Health (NIH)
The purpose of this Guide Notice is to inform the NIH extramural community that GSA’s System for Award Management (SAM) is supporting an active investigation by the Office of Inspector General (OIG) into alleged, third party fraudulent activity in SAM. At this time, only a limited number of entities registered in SAM are suspected of being impacted by this fraudulent activity and have been notified.
However, as a precautionary measure to protect the Federal government's interests as well as all recipients, effective March 22, 2018, GSA will now require entities starting a new registration in SAM.gov to provide an original signed notarized letter, on the entity's letterhead, stating that the organizational official registering the organization is the authorized Entity Administrator before the organizations registration will be activated (no exceptions).
NIH seeks to reassure the extramural community that GSA has already taken a number of proactive steps to address this issue and is in the process of making system modifications to prevent improper activity going forward. In the interim GSA expired, then deactivated, any entity registrations that appeared to have been affected. As mentioned, these entities have been notified and are being advised to validate their registration information in SAM, particularly their financial information and points of contact. Existing registrants that have not received an email notification from SAM.gov advising them to validate their registration information will be able to complete their annual registration update using the pre-existing procedures.
At this time, it does not appear that NIH recipients are impacted; however, NIH takes these fraudulent activities very seriously and will monitor activities accordingly in order to keep the extramural community up to date on next steps as it relates to the investigation.
What does this mean for NIH applicants?
SAM registration is one of several organization registrations needed to submit a grant application to NIH. NIH encourages applicants to begin the registration process at least 6 weeks prior to an intended due date to ensure all registrations are completed on time. Completing registrations is a critical component to submitting your application on-time.
Further guidance is provided through the scenarios below outlining how the new process will impact NIH applicants:
Scenario 1 - New SAM.gov registration started on or after March 22, 2018
Registrant must include an original, signed notarized letter stating that the organizational official registering the organization is the authorized Entity Administrator before the organizations registration will be activated.
Scenario 2 - Existing registrant but received email notification from SAM.gov requesting validation of entity information
As mentioned, GSA has expired, then deactivated, any entity registration that appeared to have been affected. Therefore, these entities will need to validate their registration information in SAM, particularly their financial information and points of contact. If an entity receives notification from GSA stating that the entity (organization) was impacted by this fraudulent activity and the notification is dated within two (2) weeks of the application due date, then NIH will accept the application within the two-week late window following the due date so long as all other aspects of the application are compliant and consistent with the funding opportunity announcement requirements. To be considered under this special accommodation, the entity's application Cover Letter must include a copy of the GSA notification.
Example: Entity received notification from GSA on March 22, 2018 that their entity was impacted by this issue. The entity planned on applying on the April 5, 2018 standard due date for small business applications. The entity must work with GSA to provide the notarized letter and reinstate their SAM registration. The entity will need to include the GSA notification in the Cover Letter attachment included on the SF424 R&R form of their application. The entity will have until April 19, 2018 to complete their application submission.
Requests for accommodations beyond the two-week late window will be considered on a case-by-case basis. Permission to submit late will not be given in advance. Therefore, applicants should ensure their Cover Letter attachment documents their good faith attempts to resolve SAM issues in a timely manner and includes any relevant correspondence with GSA.
Scenario 3 - Existing registrant that has not received an email notification from SAM.gov requesting validation of entity information
No action required. Entities will be able to complete their annual registration update using the pre-existing procedures. However, entities registered in SAM are advised to log into SAM and review their registration information, particularly their financial information. Entities should contact their Federal agency awarding official if they find that payments, which were due their entity from a Federal agency, have been paid to a bank account other than the entity’s bank account.
For more information on the process and FAQs go to http://www.gsa.gov/samupdate.
Please direct all inquiries to:
Division of Grants Policy
Office of Policy for Extramural Research Administration
Office of Extramural Research