The AAMC on March 30 submitted comments to the General Services Administration (GSA) (PDF) in response to a proposed data collection activity that would require entities to certify compliance with several new requirements during the registration process in the System for Award Management (SAM.gov), which manages recipients of federal financial assistance.
The SAM.gov registration is a required step prior to submitting an application for federal funds, including research grants. In the letter, the AAMC reminded the GSA that institutions already certify their compliance with relevant federal laws, including antidiscrimination laws addressed by the proposed new certifications. The association’s comments urged the agency not to move forward with proposed revisions, raising concerns that the proposed certification language references nonbinding guidance and examples that would make consistent application impossible, noting that “adding additional, vague, and non-statutory certification requirements introduces legal risk for registrants through ambiguous standards.”