Small businesses applying for U.S. National Institutes of Health funding can no longer count on delayed SAM registration or renewal to excuse a late application. In a notice released August 1, 2018, NIH says it is ending the temporary exception it had offered while registration requests were held up. The policy concerns the System for Award Management, or SAM, the federal registration system. NIH’s earlier guidance explicitly included small-business applicants. [S1][S3]

The agency ties the decision to a change by the General Services Administration. According to NIH, from June 29 an organization no longer needed an approved, notarized Entity Administrator letter on file before its SAM registration could be activated. That changes the order of registration checks. It does not establish that every notarized-letter obligation has been abolished, and the August notice gives no promised processing time for a particular applicant. [S1]

The earlier accommodation was conditional. NIH’s June 8 notice allowed a two-week late window when an organization had submitted all SAM renewal documents before the application deadline but the renewal remained unfinished. The rest of the application still had to meet the funding announcement’s requirements. Its cover letter had to show that the renewal request was timely, using evidence such as a confirmation email or screenshot. NIH applied that flexibility retroactively to due dates on or after May 25. Those instructions describe the former exception, not another two weeks available under the August announcement. [S2][S1]

Registration status and application readiness were separate problems throughout the disruption. The June guidance said NIH could neither accept an application nor issue an award to an organization without an active SAM registration. The March notice also explained that SAM was only one of several organization registrations needed to apply. The August change removes a reason for accepting a late application; it does not offer applicants a substitute for completing the required registrations. [S2][S3][S1]

For a small firm preparing a proposal, that means tracking registration renewal alongside the application work. A confirmation that renewal documents were submitted had supported relief under the June exception. Under the August notice, an unresolved SAM delay is no longer grounds for NIH to accept a late application. [S1][S2]

Source documents

  1. NOT-OD-18-215: Update - NIH Response to Registration Issues in Sam.govhttps://grants.nih.gov/grants/guide/notice-files/NOT-OD-18-215.html
  2. NOT-OD-18-188: RESCINDED - Updates to Registration Process Changes in SAM.govhttps://grants.nih.gov/grants/guide/notice-files/NOT-OD-18-188.html
  3. NOT-OD-18-162: RESCINDED - Registration Process Changes in SAM.govhttps://grants.nih.gov/grants/guide/notice-files/NOT-OD-18-162.html