Grants.gov Temporarily Relaxes SAM.gov Validation Requirement
Grants.gov has announced that, for a limited time, it will not be strictly validating whether financial assistance applicants are currently registered with SAM.gov, a move that was expected in response to recent Office of Management and Budget (OMB) efforts to ease grantee burdens stemming from disruptions caused by the Novel Coronavirus (COVID-19) outbreak.
On March 19, OMB released OMB Memorandum M-20-17, Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) Due to Loss of Operations, which stated that federal agencies may offer flexibilities to recipients that have suffered loss of operational capacity. The memo included 13 types of blanket exceptions, which OMB would reassess by June 19, at which point OMB would determine if they should be extended. Prior to issuing M-20-17, OMB released OMB Memorandum M-20-11, Administrative Relief for Recipients and Applicants Directly Impacted by the Novel Coronavirus, which had no set timeframe and enabled agencies to provide flexibilities to a narrow scope of recipients “in instances where the agency has determined that the purpose of the federal awards is to support the continued research and services necessary to carry out the emergency response related to COVID-19.”
One of the flexibilities enabled agencies to relax the requirement for applicants to have SAM.gov registrations when applying for awards “to expeditiously issue funding.” Current registrants in SAM.gov with active registrations expiring before May 16, will be afforded a one-time extension of 60 days. In response, a recent Grants.gov release notice states that Grants.gov will not validate the SAM.gov expiration date at the time of submission, and this validation relaxation will remain effective until the flexibilities expire. However, Grants.gov still encouraged applicants with expired SAM.gov registration to go ahead and renew their registrations, as awarding agencies will perform DUNS and SAM.gov validation checks at the time of award.
Nonfederal agencies also should communicate with their awarding agencies to determine how they are implementing the 13 flexibilities allowed under the OMB memoranda, as not all agencies are expected to implement them the same way.
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