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Ask an Expert: Q&A with Ricardo Willis on New SAM Registration Changes

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Baobab trees in Madagascar silhouetted at sunset
Photo credit: USAID
Apr 19, 2023
Ricardo Willis, Systems Support Branch Chief

Ricardo Willis is the Systems Support Branch Chief in USAID’s Management Bureau, Office of Acquisition and Assistance.

Could you please describe the recent changes to the System for Award Management, or SAM, registration requirements?

Sure. The General Services Administration, or GSA, announced in February that organizations that are only seeking assistance awards are no longer required to obtain CAGE/NCAGE [Commercial and Government Entity/NATO Commercial and Government Entity] codes. This is mainly pertinent for our non-U.S. entities. They no longer will have to procure an NCAGE code, which could sometimes take anywhere between a week to several months depending on the country they were located in. The NCAGE process is managed by NATO and the Ministry of Defense for the individual countries in which the entities reside. And as a result, the process of obtaining an NCAGE code could vary from country to country. This decoupling of the CAGE/NCAGE requirements for assistance-only opportunities will completely eliminate huge swathes of time that our partners were experiencing in getting their registration in SAM.

When did this change take effect?

February 14 [2023].

What is the background about this change, and why is this happening now?

This request has been out there for several years. With the implementation of the Unique Entity Identifier, or UEI, this past April and the backlog in entity validation issues that the entirety of the federal government was experiencing with all of our partners, we reached back out to GSA and OMB [Office of Management and Budget] in conjunction with a lot of our other federal agencies that provide foreign assistance. Although the NCAGE requirement is not specifically identified in the CFR [Code of Federal Regulations, for assistance], it is a requirement in the FAR [Federal Acquisition Regulations, for acquisition], therefore a Department of Defense (DoD) requirement. However, OMB OFFM [Office of Federal Financial Management] and GSA worked with DoD [Department of Defense] and were able to get them to lift the NCAGE requirement for international entities not seeking financial assistance from DoD. As a result, a system update request was created in GSA in order to implement this new change.   

Could you tell me a little bit about how this change will help partners?

It will help them greatly. As I said, the timeframe for registration in SAM is dependent upon several issues, one being the CAGE/NCAGE requirement. Sometimes the country where our partner is located determines how short or how long it takes for them to procure an NCAGE code. Entities in Kosovo, for example, have had an issue with NCAGE even being provided because Kosovo is not recognized by NATO as an independent country. The workaround was to request their NCAGE from Serbia. That created an issue because of the fact that Serbia just does not recognize Kosovo as an independent country. In addition, the U.S. Ambassador to Kosovo made a request that Kosovo partners not register or not obtain NCAGE because the only way to do so would be to identify themselves as a Serbian entity. So, in fact, possible entities were no longer able to get an NCAGE code. So just using this as an example, the new change is a huge win for our partners in Kosovo that are pursuing assistance-only opportunities. For our other partners, again, because of the time that it takes to get an NCAGE code, not having to obtain one significantly reduces the time it takes to register in SAM.

If I'm an organization coming to register to work with USAID, how would I know if this change applies to me and my organization?

If you're only pursuing assistance opportunities, then this will apply to your organization.

What if I had already started my registration for assistance awards before February and now I'm in the middle of the process. Do I need to do something different?

Yes. The qualified entities who currently are in a work in progress (WIP) status, which means they've started their registration for assistance-only opportunities, can create an incident at the Federal Service Desk, or FSD, meaning they can create a ticket and request to reset their CAGE and NCAGE code requirements status. The ticket should include the following language: “I do not intend to seek financial assistance from the Department of Defense. I do not wish to obtain a CAGE or NCAGE code. I understand that I will need to submit my registration after this incident is resolved in order to have my registration activated.” So, yes, there is a workaround if you are in a work in progress status and you're only pursuing assistance opportunities. And the language that I just provided is how you are able to take advantage of that CAGE/NCAGE decoupling.

What if my SAM registration has expired and I'm trying to renew it?

GSA is currently working on a solution to this issue. Once it is implemented, assistance-only registrants will have an option to remove their CAGE and NCAGE when they renew the registration. A change request ticket has been created within GSA. Unfortunately, I can't provide you with a timeline on when this change will be implemented. But GSA is aware that folks will want the ability to decouple their CAGE and NCAGE code if they're only pursuing assistance opportunities and they are working to create that change.

If I'm an organization that's only seeking assistance awards, is it accurate to say that I only have to register in one system, which is SAM, now? 

So, with UEI, if you were a U.S. entity, you only had to register in SAM.gov. That was one of the benefits of UEI – it was kind of one-stop shopping. Unfortunately, that change did not apply to non-U.S. entities; they still had to go to NCAGE to obtain their NCAGE code and then go to SAM.gov. Now, those seeking assistance-only opportunities will only have to register on SAM.gov.

So the biggest change is for those non-U.S. assistance-only organizations – is that accurate?

That is accurate.

Will these organizations ever have to obtain a CAGE or NCAGE code at any time in the future? 

Only if they are seeking to pursue both contract and assistance opportunities in the future. So if they change to include contract opportunities, then they will have to obtain a CAGE or NCAGE code.

If I'm an organization that initially wanted to only apply for assistance awards and then decided I wanted to apply for a contract, would I then have to go back and obtain that CAGE or NCAGE code?

Yes. There's a question in SAM that asks whether you're seeking contract opportunities, assistance opportunities, or both. If you are changing from assistance-only to assistance and contracts, you would have to select contracts and that would actually force you to get a CAGE or NCAGE code.

How will this change affect the average timeframe for registration? 

Once all the required documentation has been uploaded and validated, the registration should be completed within one to two days. The caveat is around the part where I said “all the required documentation has been uploaded and validated.” The issue is that the documentation requirement is still causing some delays because entities are struggling with uploading the proper documentation and/or uploading translated documentation accurately. But once all of that is done, the registration should be completed within one or two days.

If I'm a new partner who is having trouble with the system or has run into some roadblocks, where should I go? Who should I consult?

Well, it depends on where you are in the process. For example, if you are a partner who's trying to renew and you have an existing award with USAID and you have already created an incident ticket, you can work with your Contracting Officer or Agreement Officer. We have created an escalation process for this scenario. If you are a new partner and you're about to be awarded a grant or contract, again, you can work with your USAID point of contact and they can follow the escalation process that's been documented, and we will escalate it on your behalf. 

However, if you don’t have a point of contact within the Agency, then I would recommend going to the SAM Help Desk which is FSD.gov. You can either call – and the phone number is on their website – or you can chat online within their hours of operation, and they'll create a ticket and help you work through whatever issue you’re having. Or you can create an incident by completing a webform on the website as well. So there are three ways to contact the Help Desk either by phone call, chat, or webform. Then they'll respond back to you on your issue by email or in your FSD workspace.

Getting up to speed on recent changes to the entity registration system? Check out our previous Q&A with Ricardo Willis about the Unique Entity Identifier (UEI) process, which was introduced in April 2022.