The latest updates and analysis from Morrison Foerster
February 27, 2023 - Federal Procurement Is Changing – Make Sure You’re Keeping Up

GAO Finds CIO-SP4 Solicitation Is Unduly Restrictive of Competition

The System for Award Management website ( recently changed its registration and update process, and the feedback we’ve heard from clients is that it is slow – even for entities that are simply renewing an existing registration. As SAM delays can cause payment delays, the best advice is not to leave renewing your SAM entry until the last moment. This is the case because SAM’s update process requires entities to verify their business against a database of organizations and addresses, leaving plenty of room for mismatches, human error and confusion. This process is required to register in or to get a Unique Entity ID.

Lacking a registration in SAM can preclude you from receiving federal contracts, and failing to register promptly or maintain an up-to-date registration can be costly – just ask the protester in this recent decision by the U.S. Court of Federal Claims,[1] whose proposal for a $76 million contract was rejected (rightfully, said the court) on that basis alone. The practical consequences for having mismatched information can also be dire and will certainly require the most valuable resource: time. Even if your previous interactions with have been swift and painless, much has changed, and companies should ensure all their paperwork is in order and allow plenty of time to complete the process

What is the Process?

Entity validation is required when contractors register an entity, renew their entity registration each year, get a Unique Entity ID, and update or change their entity’s name or address. 

Regardless of whether an entity is new to or is already in, the process requires entering entity information and finding your company among the Entity Validation Service records.

Happily, if an entity is in the results and all information is correct, then the process is relatively simple. Unhappily, even in this scenario, entities may be required to submit documentation. This is also the case for updating or correcting information on In short, all roads lead to submitting documentation that may not have been submitted for many years.

If a contractor must submit documentation, will generate an entity validation incident. We’ve heard that these incidents are stacking up, leading to delays and frustration. Contractors can keep track of this incident through an entity validation ticket that Federal Service Desk (“FSD”) will monitor. This ticket will be the one-stop shop for Entity Validation.  Contractors will upload validation documentation to this ticket through, and FSD will contact contractors for validation results using the ticket.

Do not submit multiple validation tickets for the same issue. Doing so risks prolonging the entity validation process.

Who Can Complete the Process?

Each SAM registration requires an “Entity Administrator” role, generally assigned to the first user to complete the registration. The Entity Administrator can perform a number of actions, including viewing the entity’s entire entity organization, updating and renewing the Entity Management registration, deactivating the Entity Management registration, and approving or rejecting hierarchy registration requests. Contractors may have multiple Entity Administrators.

Effective as of March 3, 2023, the Entity Administrator must be an employee, officer, or board member of the entity. If a user who currently manages a contractor’s registration is not an employee, officer, or board member, the user role will change from “Entity Administrator” to “Data Entry.” Under the Data Entry role, that individual can continue to create and manage registrations on behalf of entities, but cannot manage roles for the entity (e.g., assign new Entity Administrators or Data Entry roles).

If for some reason access to the Entity Administrator role is lost – if, for example, the assigned Entity Administrator leaves the company before reassigning the role to someone else -- an executive, officer, partner, or other authorized signatory for the company must request reassignment of the role. This process requires sending FSD a signed letter, that will likely need to be notarized. Contractors should thus take care to review role assignments when renewing their registration. 

What Documents Suffice? 

Contractors must submit documents verifying the following:

  • List A: Name and/or Address
  • List B: Start Year and State of Incorporation
  • List C: National Identifier (if an international entity)

Common documents for List A include

  • Articles of Incorporation/Organization/Formation (if stamped as filed with an authority)
  • Bank Statements (redacted for any information unnecessary for validation)
  • Certificate of Formation/Organization (if stamped as filed with authority)
  • Department of Treasury IRS letter assigning entity’s EIN
  • Utility Bill (water, gas, or electric only)

For tax returns, filings, or bank statements, contractors should redact or limit information present on these documents. FSD only requires the relevant data needed to validate the company and the entity on

Common Documents for List B include

  • Same documents as List A, as long as they include the state and month, day, and year of incorporation (U.S.-based entities)
  • Same documents as List A, as long as they include the country and month, day, and year of incorporation (non-U.S.-based entities)

Common Documents for List C include

  • Screenshot/PDF file of the entity’s business profile in entity’s country’s official online business registry (Screenshots of U.S. federal websites are not permitted)
  • Government-issued proof of tax identification number, employer identification number, or other identifier issued by the entity’s government
  • Government-issued tax receipt/return
  • Passport (for sole proprietors or individuals doing-business-as only; must be non-expired and have the entity’s exact name and address)

What Should I Avoid?

Contractors should be aware that some documents must be authenticated. Additionally, federal contract awards will not be accepted for validation.

  • Other common pitfalls for validation rejection include

    Old Documentation. For example, a document generated on a monthly or annual basis (such as a bank or utility statement) must be from the last five years. 
  • Incorrect Information. Contractors should not upload contradictory information. For example, if you request updating the legal name of your company to “ACME Company,” do not provide a business license showing its name as “ACME, Inc.”
  • Using a P.O. Box as an Address. These will always be rejected.
  • Attaching Non-English Originals Without a Certified English Translation.  Translations must be line-by-line and accompany the original content.
  • Unapproved Documentation. All documents must be official, and pending applications or screenshots will be rejected.
  • Poor-Quality Documents. Low-contrast documents or obscured information will be rejected.
  • Vague Request. The text box on the documents page is optional and does not need to be filled in. However, if you do add a request, use the text box to explain anything that could help FSD understand the connection between what is entered on the screen, the entity you selected, and the documents you provided.

Additionally, validating information must match the data in exactly.

FSD will review the documentation and send an email with the results of their review. Take care to monitor for this email.  If an entity does not respond to the request for information or additional documentation within 5 business days, it will have to restart this process.

Be aware that manual review will take time. FSD claims that manual review takes an average of four days, but as contractors upload their documentation, manual review is likely to take longer.

Once review is complete, an entity must go back to and finish registration or get a Unique Entity ID.

Updating Information? The Process May Take Longer.

If a contractor is updating its information, the process does not end here. Multiple agencies will validate the information.

Once an entity submits its registration, the IRS will validate the name and taxpayer identification number.

The Defense Logistics Agency will validate information as well.  This process can take up to 10 business days.

If the validation fails at this point, an entity will receive an email with instructions to update the information and resubmit registration.

When Should I Validate? Sooner Rather Than Later.

Contractors should be aware that changes to SAM have increased the administrative burden of maintaining a registration, but doing so – and making sure that SAM registration remains up-to-date – is no less important than it always has been. With all contractors being submitted to this process, SAM/FSD resources have been heavily taxed, resulting in massive delays for entity validation.  If you must update your information on or your registration expiration is coming up, the wisest course of action is to get ahead of the registration process and get started on this right away.

[1] Thalle/Nicholson Joint Venture v. United States, No. 22-755, slip op. (Fed. Cl. Jan. 27, 2023). 

*Thomas Lee contributed to this blog post. Thomas is a full-time law student at The George Washington University Law School and a Law Clerk with Morrison Foerster’s government contracts practice group.