Does a nonprofit need to register in SAM.gov?

SAM.gov asks for the purpose when an entity is started, and it describes two registrations in its own words. Financial Assistance Awards is for applying for grants and loans as 2 CFR 200 describes them. All Awards adds bidding on federal contracts and other procurements as the Federal Acquisition Regulation describes them. The registration checklist says the same. All Awards lets you bid on contracts and also apply for financial assistance. Financial Assistance Awards Only lets you apply for grants and loans, and nothing more.

The checklist also lists what each registration asks. Financial Assistance Awards Only has four sections: Unique Entity ID, Core Data, Reps & Certs and Points of Contact. All Awards adds Assertions, the Architect and Engineering responses, the Defense FAR Supplement questionnaire where it applies, and the SBA supplemental page for a small business. SAM.gov's questionnaire recommends Financial Assistance Awards Only to an entity that wants to work directly with the federal government by applying for a grant or loan, but not for contracts. The Federal Service Desk's article says the questionnaire is only a suggestion tool and that any of the options can be chosen. Do you register in SAM.gov for contracts, grants, or both? goes through the choice and the certifications each purpose asks.

Usually not. SAM.gov's comparison of its purposes marks the CAGE code as issued to some entities under Financial Assistance and to every entity under All Awards. The questions SAM.gov asks before a Financial Assistance registration mention a CAGE code only when the entity applies for or receives financial assistance from the Department of Defense. The Federal Service Desk's article says a CAGE or NCAGE is not required for Financial Assistance Only. It is required if you register to receive funding from the Department of Defense or will bid on procurement contracts. CAGE codes explained covers the code itself.

A UEI alone is a Unique Entity ID without a registration. SAM.gov's comparison lists Unique Entity ID Only as a third option. It gives the entity a UEI and makes it available in search. It validates the entity's name and address, and it has no taxpayer validation, no CAGE code and no expiration. It does not let the entity apply directly for federal grants or loans, or bid on federal contracts as the prime. It does let the entity receive an award from someone else who receives federal funds. SAM.gov's questionnaire recommends it to an entity that plans to receive a subaward under a federal grant or financial assistance program. It also recommends it to an entity that plans to apply for federal funds a state, local, tribal or territorial government distributes. Its recommendation text describes that entity as one that does not intend to do business directly or indirectly with the federal government.

The organization distributing the money may still ask for more than the identifier, and its own terms say so. Do you need only a UEI, or a full SAM.gov registration? explains the identifier-only path and why it is not a way around a registration's certifications.

A nonprofit that receives a subaward needs a UEI, not a full registration. A recipient may not make a subaward to a subrecipient that has not obtained a UEI and given it to the recipient. Subrecipients do not have to complete a full SAM.gov registration to get one (2 CFR 25.300). A subrecipient is an entity that receives a subaward from a pass-through entity to carry out part of a federal award. A subaward is the award the pass-through entity provides for that purpose, and it does not include payments to a contractor (2 CFR 200.1). Whether a nonprofit's agreement is a subaward or a contract is the pass-through entity's determination (2 CFR 200.331). Do subcontractors need a SAM.gov registration, or only a UEI? goes through that determination and what a pass-through entity records about a subrecipient.

A subrecipient may also receive other federal awards directly from a federal agency (2 CFR 200.1). So a nonprofit that receives subawards and later applies to an agency itself registers then, as an applicant. The identifier it already has stays the same.

The sections are the same for a nonprofit as for any entity. They ask for the legal name and physical address as the formation documents record them, the start date and fiscal year end, the taxpayer identification number for the IRS check, the points of contact and, for payment, banking details. What to have ready before you register in SAM.gov lists them. Under Financial Assistance the organization also makes the general certifications and representations SAM.gov asks of an applicant for federal financial assistance, which the checklist's appendix sets out. Each one is the organization's own statement, answered by the person the organization names. This guide says they exist and suggests no answer.

This guide cannot say whether a particular program or funder asks for more than 2 CFR 25 does, because agencies and pass-through entities add their own terms. It does not name the other registrations a program may ask for. It read Grants.gov's applicant registration page, not its organization registration pages, and none of SAM.gov's own help pages. So it relies on the rules, that page, SAM.gov's checklist and SAM.gov's purpose screens as they were read while an entity was started.

Firmenza's copilot asks SAM.gov's questions one at a time for either purpose, Financial Assistance or All Awards, and we complete your SAM.gov registration from your answers. A Firmenza specialist reviews your application. How to register your business in SAM.gov is the order of the work, and a nonprofit follows it the same way.