The System for Award Management (SAM) is the primary registrant database for entities to do business with the U.S. Government. You must register with SAM before applying for a seed fund from the government for your startup.

SAM Registration

Guides:

• SAM User Guide.
• How to Complete SAM Registration

Steps for System for Award Management (SAM) Registrations:

1. Go to www.sam.gov.
2. Create a Personal Account and Login.
3. Click “Register New Entity” under “Register/Update Entity” on your “My SAM” page.
4. Review Registration Overview and click “Start Registration”
5. Select the type of Entity (typically “Business or Organization”)
6. Select “Yes” for “Do you wish to bid on contracts? Then Click “Next”
7. Confirm Purpose and Click “Next”
8. Complete “Core Data” as follows:

• a. Validate your DUNS information.
• b. Enter Business Information (TIN and so on).
• c. Enter the CAGE code if you have one. If not, one will be assigned to you after your registration is completed. Foreign registrants must enter an NCAGE code.
• d. Enter General Information (business types, organization structure, etc.).
• e. Financial Information (Electronic Funds Transfer (EFT) Information).
• f. Executive Compensation.
• g. Proceedings Details.

9. Complete “Assertions” as follows:

   • a. Goods and Services (NAICS, PSC, etc.). NAICS is required. PSC is optional.

     • NAIC: North American Industry Classification System (NAICS) Codes are a method for classifying business establishments. You must select at least one NAICS Code indicating the industry in which you offer goods or services before your registration can be complete. If you do not know the NAICS Code(s) for your industry, search http://www.census.gov/eos/www/naics/. You can add or change NAICS Codes at any time. The NAICS Codes you enter here will be used by the government for market research.

     • PSC: Product Service Codes (PSC) are optional, four-character, and alpha-numeric codes used to identify the products and/or services your entity provides. Federal Supply Codes (FSCs) are a subset of the PSCs. You may search for PSC Codes here

     • Facebook’s NAICS Code is 518210 for Data Processing, Hosting, and Related Services and SIC Code is 7374 for Computer Processing and Data Preparation and Processing Services.

     • LinkedIn’s NAICS Code is 541511 for Custom Computer Programming Services.

     • Github’s NAICS Code is 541511 as well.

       Since I think LooseLeaf is like LinkedIn meets Github, I selected NAICS Code 541511. I didn’t select a PSC.

   • b. Size Metrics.

     You need to fill out how much money you made since incorporating the company (average over the last x years since incorporation) and how many employees you have, including yourself.

     Total Receipts means “total income” (or in the case of a sole proprietorship, “gross income”) plus “cost of goods sold” as these terms are defined and reported on Internal Revenue Service tax return forms. Receipts are averaged over a concern’s latest three (3) completed fiscal years to determine its average annual receipts.

     It won’t let you enter $0, so I entered $1 and it went through. 😕

   • c. EDI Information: This asks if you want to provide your Electronic Data Interchange (EDI) information.

     • Click No

   • d. Disaster Relief Information:

     • Click No.
10. Complete “Representations and Certifications” as follows:

    • a. FAR Responses

      • Who are the person(s) within responsible for determining prices offered in bids/proposals? (FAR 52.203-2):
        • Enter your name and title.
      • Does have other plants/facilities at different addresses routinely used to perform on contracts? (FAR 52.214-14, FAR 52.215-6):
        • Select No.
      • TIN is on file. (FAR 52.204-3, FAR 52.212-3)
      • For products designated by the Environmental Protection Agency and provided by , does the percentage of recovered material content meet the applicable EPA guidelines? (FAR 52.223-4, FAR 52.223-9):
        • Select yes, even if your company’s business has no environmental concerns.
      • Is a small business concern that wishes to be considered for status as a labor surplus area (LSA) concern? (FAR 52.219-2):
        • Select No.
      • Is owned or controlled by a common parent, that files its Federal Income Tax returns on a consolidated basis? (FAR 52.204-3, FAR 52.212-3):
        • Select No.
      • The rest of the questions deal with any criminal activities on record associated with the company or any of its principals. Select No for all of them.
      • Does provide any data to the Government that qualifies as limited rights data or restricted computer software? (FAR 52.227-15)
        • Select No.
      • Our records indicate that LooseLeaf, LLC Org Type is “Other” please enter more information here. (FAR 52.204-3, FAR 52.212-3):
        • Enter “Disregarded Entity - Single Member LLC” as shown on the SS-4 Form.
      • Are you a Small Disadvantaged Business?
        • Select Yes.
      • Has filed all required Equal Employment Opportunity compliance reports? (FAR 52.222-22, FAR 52.212-3)
        • Select No and for the next question, select “” does not have developed and does not have on file affirmative action programs required by Secretary of Labor regulations."
        • See EEO-1 Who Must File. Single Member LLC don’t have to file.
      • Does provide maintenance, calibration, and/or repair of information technology, scientific and medical and/or office and business equipment? (FAR 52.212-3, FAR 52.222-48)
        • Select No.
      • Does provide services as described in FAR 22.1003-4(d)(1)? (FAR 52.212-3, FAR 52.222-52)
        • Select No.

    • b. Architect-Engineer Responses.

    • c. DFARS Responses.

11. Complete “Points of Contact”.
12. Before Submitting:
    • Per new policy,submission of an original, signed notarized letter identifying the authorized Entity Administrator for the entity associated with the Data Universal Numbering System (DUNS) number is required before the registration will be activated. See instruction for domestic entities

Pro-Tip and Gotchas

You may get an error from SAM when everything is ready to go and you press the “final Submit” button.

Mandatory Errors. SBA Supplemental Page was not available due to the following error: SAM did not receive a URL from SBA.

I followed this tutorial to request/create an account with SBA’s General Login System at https://eweb.sba.gov/gls/dsp_login.cfm. I created a profile and logged in with my username and password. Then clicked on “Profile” from the menu and added a new business. You just have to enter DUNS and EIN. Then I went back to SAM and tried to submit again. It went through. I don’t know if it was an intermittent error with SAM or that step was necessary.

After Submitting

SAM will send your application to the IRS for validation of your Taxpayer Identification Number (or EIN) and Taxpayer Name. This could take two business days. Then SAM will send your application to the Defense Logistics Agency (DLA) Commercial and Government Entity (CAGE) Code system for assigning you a new CAGE Code. You’ll get an email from sam.gov once your registration passes these external validations and becomes active.

Gotcha

Gotcha: Annual Reports

It was four weeks before the deadline for NSF grant application and 10 days after I submitted the SAM application. The DLA contacted me about presenting proof that my business is in good standing with the state in which it was registered in. Specifically, the email stated:

We are unable to determine the status of your legal business name from the Secretary of State (SOS) where you indicate your business is physically located according to the address accepted within SAM. Please provide either a current statement of good standing, current Articles of Organization/Incorporation dated within the last 12 months or a screen shot of the status obtained from the SOS. If your company is incorporated within another state, then please provide the current legal business name documentation from that state that shows your company is active and/or in good standing.

Please respond by replying to this email within five business days and provide an answer to the question above. If CAGE does not receive a response within five business days, your SAM registration will be returned and you will have to start the process over at WWW.SAM.GOV.

After some googling, I found this Fundera article which explains how to check that your business is in good standing with your state. I registered LooseLeaf as a LLC with Washington, DC so I followed the link from the article to go to the Department of Consumer and Regulatory Affairs (DCA) Website (corponline.dcra.dc.gov)

This website which is DC’s website for looking up information about your company’s status. Registering and looking up LooseLeaf on the site was really easy and took a minute. But to my astonishment, the entity status for LooseLeaf is “revoked”. 😱

So I had five days to figure out how to turn LooseLeaf’s entity status from “revoked” to “active”.

After making some frantic calls first to LegalZoom, who said they had no idea that LooseLeaf is no longer in good standing with DC (because they’ve not received any letters or notifications about it) and referred me to call the states department, who then referred me to call the DCA, who then transferred me to call the corporation office (202-442-4432). I finally got an answer.

I talked to a person called Phil from DCA’s corporation office on the phone who was really helpful. He immediately told me the status is “revoked” because I didn’t file a form that I was supposed to file within one year of incorporation. That form is called BRA-25. After the initial filing, the requirement is to file it every other year. I created the LLC on 7/31/2016 through LegalZoom as my registered agent and I was supposed to submit the BRA-25 form using the (corponline.dcra.dc.gov) by April 2017. When I didn’t by September, LooseLeaf’s entity status became “revoked”.

Phil told me that in order to turn the “revoked” status to “active”, I need to retroactively submit the BRA-25 form for 2017 then submit the GN-5 form of reinstatement. BRA-25 costs $400 to submit and GN-5 costs $300, but if I want to expedite their processing of the GN-5 form, I can pay an extra $50 to get the status turn back to an “active” in 3 days or pay an extra $100 to get it back to an “active” within 24 hours.

I filled out those two forms. It took me 10 minutes total. You just verify your information is correct, then you fill out a form with your credit card information so they can take $800 from you. I called Phil the next day to ask about the status and he told me he’ll click me through now. One button click later, he told me to refresh the page and like magic, “revoked” turned into “active”. $800 please. 😞

A big gotcha and lesson learned is know the requirement and be compliant with the state law so you can stay in business. I didn’t know DC is one of those states that require the companies to file periodic reports with the state through (corponline.dcra.dc.gov). I retroactively submitted the report with DC at a great cost. I set calendar reminders for myself that the next time I need to submit the BRA-25 form is in 2019 (and after that, 2021), which keeps LooseLeaf in good standing with the state. You need to be in good standing with the state so you can get loans or government grants for your startup. I don’t know about angel or venture capital investors but I think they prefer you to incorporate as a Delaware C-corp, but that’s another story.

Another lesson learned was I wrongfully thought LegalZoom would take care of everything when I registered LooseLeaf as a LLC with Washington, DC. LegalZoom acts as your registered agent but they don’t have an obligation to your business to keep you in good standing with the state. They still take your money every year to continue to be your registered agent but it’s your responsibility to file your annual reports with your state as needed and file your taxes. You can get LegalZoom to do more for you but you have to pay them.

Finally, Make sure your business is active in the state in which you registered BEFORE you apply to SAM and start SAM application early. Assume that everything that could go wrong will go wrong. If I had started with my application two months earlier instead of a month earlier, I wouldn’t have to pay that extra $100 to get the reinstatement expedited or freaking out about the 5 days I have with DLA to get the CAGE number established for SAM. You need to have an active SAM before you can even start the actual NSF application.