FR 2025-01755

The document from the Federal Register discusses proposed revisions by the General Services Administration (GSA) to rules surrounding notarized document submissions required for registering new entities in the System for Award Management (SAM). This initiative aims to enhance security and accuracy within SAM, a crucial system for federal government acquisitions and assistance programs.

General Summary

The GSA, an agency responsible for federal acquisitions, is tweaking the existing procedure to make it more efficient. Currently, notarized letters are required for all new entity registrations. Under the new proposal, these letters would only be necessary when appointing a new administrator for already-existing entities where no administrator is currently on file. This should reduce unnecessary paperwork and streamline processes for businesses looking to engage with federal contracts or assistance programs.

Significant Issues and Concerns

One critical issue is the document's lack of detailed cost analysis regarding the salaries used for burden calculations—$150 per hour for executives and $100 for officers seem arbitrary without specific justification. Such vague estimates may foster skepticism about potential wasteful spending.

Another concern is the ambiguous language describing labor expectations, particularly when referencing "an individual equivalent to a GS-5, Step 5 Administrative Support person." This could lead to confusion over what level of effort or expertise is required for completing the tasks outlined.

Moreover, the estimated external notarization fee of $5 might not capture the actual costs that third-party notaries charge across different regions, leading to potential budgeting inaccuracies.

The notice also mentions no public comments were made following an earlier publication, which raises concerns about the level of public awareness and engagement on such a significant change. Lastly, the assumption that large businesses inherently have in-house resources for notarization might not be accurate without data supporting this claim, potentially misguiding compliance cost projections.

Impact on the Public and Stakeholders

For the general public, particularly businesses trying to interact with federal institutions, these changes could reduce administrative burdens, making it easier and quicker to register entities in SAM. However, some might feel uncertain due to the issues mentioned regarding costs and labor requirements.

Small businesses may view the requirement for notarization as an additional hurdle—especially when lacking in-house resources—which could mean extra out-of-pocket costs and delays in engaging with government contracts. Conversely, larger businesses with in-house notaries may find the changes align well with their operations, potentially easing their registration processes.

In summary, while the intentions behind the proposed changes aim to simplify and secure the SAM registration process, there are several points within the document that could benefit from further clarification and justification to ensure transparency, fairness, and informed participation from all concerned parties.

The document from the General Services Administration (GSA) concerning the System for Award Management (SAM) includes several financial references that offer insight into the projected costs and assumptions necessary for implementing the notarized document submittal process.

Summary of Financial References:

The GSA estimates the cost for tasks associated with submitting notarized documents in SAM by assuming various hourly rates for different roles involved. For example, the estimated hourly rate of $25.06 is used for a "GS-5, Step 5 Administrative Support person" within the government who would perform tasks such as creating and uploading notarized letters. Additionally, there is an assumption that large businesses will have executives or officers sign notarized letters at a rate of approximately $150 per hour, whereas small entities might incur costs with an hourly rate of approximately $100 per hour for the same task. Those using third-party notaries might face an additional $5.00 fee, which is cited as a nominal charge.

Relation to Identified Issues:

One of the key issues associated with these financial references is the lack of detailed cost analysis or justification for the average salaries used in the burden estimate calculation. For example, while the document states the hourly rates of $150 and $100 for executives and officers in large and small businesses respectively, there is no information on how these figures were derived or why they are considered reasonable. This could lead to skepticism regarding the accuracy of these figures and fuel concerns over wasteful spending.

Moreover, the estimated external notarization cost of $5.00 may not fully capture the geographical variations and actual fees charged by third-party notaries across different regions. This omission could result in discrepancies between projected and actual costs, leaving some entities potentially unprepared for the financial burden.

Additionally, the presumption that large businesses have in-house resources for notarization lacks supporting evidence. This assumption influences the projected compliance costs but could lead to inaccuracies if not all large businesses have ready access to these resources internally—a common misconception that could have financial implications.

Furthermore, the document's technical language, along with the financial assumptions, might create barriers for stakeholders who are not familiar with government procurement and acquisition processes. This lack of clarity could hinder effective public engagement and contribute to insufficient feedback on important financial decisions impacting stakeholders. The absence of public comments following a previous notice supports this concern, highlighting the need for improved communication and stakeholder involvement in financial matters discussed in the document.