Document
Submission for OMB Review; System for Award Management Annual Certification of Compliance With Executive Order 14400, Urgent National Action To Save College Sports
Under the provisions of the Paperwork Reduction Act, the Regulatory Secretariat Division will be submitting to the Office of Management and Budget (OMB) a request to review and ...
SUPPLEMENTARY INFORMATION:
A. Purpose
Executive Order 14400, Urgent National Action to Save College Sports, directs the Administrator of General Services to propose a regular collection of information to evaluate compliance with the rules covered in the E.O. to aid contract and grantmaking agencies' compliance with the E.O. starting August 1, 2026.
The System for Award Management (SAM or
SAM.gov) serves as the primary registration and award management database for the U.S. Federal Government. SAM currently collects, validates, stores, and disseminates data in support of agency acquisition and financial assistance missions. SAM validates entity registration information and electronically shares the secure and encrypted data with Federal agency personnel to facilitate their award making and payments. Additionally, SAM shares its data with Federal Government procurement, financial assistance, and electronic business systems.
Both current and potential Colleges and Universities are required to register in SAM pursuant to
Title 2 of the Code of Federal Regulations (CFR) and the Federal Acquisition Regulation (FAR) to receive specified Federal awards. Entities complete a registration process to provide basic information relevant to procurement and Federal financial assistance transactions. These entities may also report various information applicable to the federal award process in
SAM.gov.
Registered entities identified as Higher Education Institutions during the SAM entity registration and meeting the $20M (adjusted for inflation) threshold for intercollegiate athletics activities revenue will certify their compliance annually with the terms within E.O. 14400. This certification information will be available for Federal officials for contract and grantmaking activities and compliance verification.
B. Annual Reporting Burden
Respondents:
11,720.
Responses per Respondent:
1-5 (1 for screening responses and 4 for certification responses).
Total Annual Responses:
14,620 (11,720 screening responses and 725 certification responses).
Hours per Response:
0.25 for screening response and 0.5 for certification response.
Total Burden Hours:
$181,584.50 ($161,589.50 for screening response and $19,995.50 for certification response).
C. Public Comments
A 60-day notice published in the
Federal Register
at 91 FR 36143 on June 16, 2026. One Comment was received covering several different topics.
Comment:
A general concern that the certification could influence eligibility determinations, payment processing, grant and contract actions, and compliance reviews, and that it could be an opaque enforcement mechanism.
Response:
This information collection covers the collection of certification information in
SAM.gov
to centralize collection and aid contracting and grantmaking agencies compliance with section 4(a) of E.O. 14400. Eligibility, award determination, and payment are awarding agency functions and not within scope of this information collection.
Comment:
A comment that the information collection burden should include burden associated with institutional review, legal analysis, data gathering, and internal approvals in a university institution.
Response:
The estimated hours in this information collection covers the administrative time for registrants to review, prepare, and complete or update the SAM registration. Costs for legal analysis are pre-existing obligations related to compliance with existing laws and regulations and are not new burdens created by this administrative ICR.
Comment:
Clarify how the $20M in athletics revenue should be calculated.
Response:
Calculation of the $20M in athletics revenue should be calculated based on the guidance in E.O. 14400 Section 3.
Comment:
Clarification on which agencies or officials may access certification data and for what purposes.
Response: SAM.gov
data is available for all federal agencies to access and utilize as needed for their agency mission.
Comment:
Clarification on whether certification data may be used to delay, suspend, terminate, deny, or condition federal awards.
Response:
Agency use of
SAM.gov
data is outside the scope of this information collection and would be governed by the awarding agency's policy and processes.
Comment:
Clarification on whether institutions will receive notice, an opportunity to correct errors, and an appeal or review pathway before adverse action is taken.
Response:
Issuance of suspension and debarment or other adverse actions are outside scope of this information collection and are governed by existing law and regulation.
Comment:
Recommendation that
SAM.gov
preserves version history and audit logs, submission timestamps, corrections, and resubmitted records.
Response: SAM.gov
as a matter or practice maintains record versions, audit logs, time stamps, and other relevant record data to validate the record submission and its associated audit characteristics.
Comment:
Recommendation that
SAM.gov
preserves documentation of agency reliance on certification data.
Response:
Agency utilization of
SAM.gov
or other sources as part of contract or grant award making is maintained within agency files and not within
SAM.gov.
Richard Speidel,
Deputy Chief Data Officer, General Services Administration.