Section 3: Doing Business with the U.S. Government -- Important Registrations

In order to do business with the U.S. government, you will need to be able to access a number of online systems. As a new executive director, you will need to make sure your name is registered in all the necessary accounts. Here are some sites or departments where you need to register.

Connecting with ACL/OILP

Your board of directors should have already notified your CIL’s Program Officer (PO) at the Administration for Community Living, Office of Independent Living Programs (OILP) that you have been appointed as executive director. Sometimes boards don’t realize they have that responsibility, so make sure your PO has been notified in writing (email is acceptable). To find out who your PO is, go to https://acl.gov/programs/aging-and-disability-networks/centers-independent-living, scroll down about two-thirds of the way to the highlighted items, and click on the link for “Office of Independent Living Programs Contact List.” The states are listed for each region. If the Program Officer states they have not received this notice from the board, you will need to have your board chair contact the Program Officer to confirm your appointment in the position.

Payment Management System

One of the systems you will need to register in and become familiar with right away is the Payment Management System (PMS), a centralized payment and cash management system where grant recipients draw down funds and file the Federal Financial Report (FFR). The PMS Program Support Center at https://pms.psc.gov/ has links for requesting access (creating an account) and changing access. There is also a link to the PMS User Guide. The ONE-DHHS Help Desk is available weekdays from 7 a.m. to 9 p.m. ET (except Federal Holidays) to respond to questions regarding the PMS application, assist users having difficulty navigating through PMS application system menus and processes, and reset PMS user passwords. Email them at PMSSupport@psc.hhs.gov or access more services (including Frequently Asked Questions) using the Self-Help Web Portal at PMS Help Desk | HHS PSC FMP Payment Management System (https://pms.psc.gov/support/help-desk.html).

Dos and Don’ts of Drawing Funds

If your Center for Independent Living receives a direct grant from Health and Human Services (HHS) through ACL, then someone in your organization draws down funds through the Payment Management System to be directly deposited in your CIL’s bank account. This process is getting a lot of attention from the OILP, so it’s essential to know what you can and cannot do.

  • Do make sure that you are authorized to draw funds before you need to do so. There is a process to be identified as the person who can do the draws, and you don’t want to wait until the last minute when you have a cash crunch and then discover you still have to get registered as the person who can draw. (You can assign two people to the task, each with their own registration, so that you don’t run into a situation where no one can draw. Typically, the second person is a board member as a backup.)
  • Do draw down the amount you will need for the expenses currently charged to the grant. An easy way to do this is to draw down to cover the expenses for which checks were written, drawing the properly allocated amount (only the appropriate share of expenses) for the specific grant. A monthly draw or a draw that coincides with payroll makes sense since payroll is your largest expense. Have your bookkeeper or accountant run a report of the checks written and the total charged to each funding source. If you do this once or twice a month you will keep up with your actual expenses.
  • Do maintain a clearly labeled PDF of the payroll, payroll overhead calculation, other direct costs, and indirect cost allocation to support each draw. These should be retained for three years after the year of the draw.
  • Do realize that your Program Officer at ACL is reviewing the information related to your draws. There should not be a pattern, an equal amount drawn each time. You should be drawing based on actual expenses, not based on budgeted expenses or 1/12 every month. Also, do maintain documentation of decisions that may have resulted in higher expenses for a period than usual. If a CIL appears to be spending significant portions of the grant, ACL may ask if the CIL will have funds to operate for the full year.
  • Don’t draw down using your predecessor’s user ID and password, even if they left it for you or left it memorized on the computer you are using. During the process you must certify that you are the person who signed in, so make sure that is true.
  • Don’t draw down in excess of what you are spending in that period. You cannot use your draw to borrow money to pay other expenses, or to build a reserve. You should draw from your Part C grant only what you are charging to the grant, both direct and indirect expenses. This includes only the appropriate share (allocation) of the expenses that are shared. If you are having difficulty getting money on time from other funding sources, you must resolve those with the entities funding the programs.

Dun and Bradstreet (D&B) Data Universal Numbering System (DUNS)

The Office of Management and Budget requires applicants to provide a Dun and Bradstreet (D&B) Data Universal Numbering System (DUNS) number when applying for federal grants or cooperative agreements. It is a unique, nine-digit identification number. The DUNS number is free and easy to obtain, and your CIL has one if you have been receiving federal funds. If you do not know what your CIL’s DUNS number is, you can look it up at https://www.dnb.com/duns-number/lookup.html.

System for Award Management (SAM)

In order to do business with the U.S. Government, your organization must create/maintain a user account in the System for Award Management (SAM) (https://www.sam.gov/).

You can use this site for FREE to:

  • Register to do business with the U.S. government.
  • Update or renew your entity registration.
  • Check status of an entity registration.
  • Search for entity registration and exclusion records.

To register in SAM, at a minimum, you will need the following information:

  • Your DUNS Number, Legal Business Name, and Physical Address from your Dun & Bradstreet (D&B) record.
  • Your Taxpayer Identification Number (TIN) and Taxpayer Name associated with your TIN. Review your tax documents from the IRS (such as a 1099 or W-2 form) to find your Taxpayer Name.
  • Your bank's routing number, your bank account number, and your bank account type, i.e. checking or savings, to set up Electronic Funds Transfer (EFT).

If your CIL receives or has applied for federal funds, it is likely that you have a SAM account. You may need to renew your registration (it needs to be renewed at least annually), but you do not need to create a new account.

You can quickly check your CIL’s registration status in SAM by entering a DUNS Number. The SAM Status Tracker will show you the current status of your CIL’s most recent record.

If your CIL has a SAM account and you are a new director, you may need to change your authorized Entity Administrator. When registering or renewing your registration, you must submit a notarized letter signed by the board appointing the authorized Entity Administrator.

For FREE help registering in SAM, contact the supporting Federal Service Desk (FSD) (https://fsd.gov). For information on the notarized letter, go to the FSD and click on “Top Help Topics” at the top of the page.

SAM is an official website of the U.S. government. There is no cost to use SAM. There are those that will offer to manage this for you for a hefty fee. That is not necessary.

GrantSolutions

As a grantee from ACL and HHS, you will need to have an account on GrantSolutions (https://home.grantsolutions.gov/home/) to upload annual documents accepting your Part C award, applying for continuation funding, and for certain portions of ACL’s compliance monitoring.

You can contact the GrantSolutions Help Desk at help@grantsolutions.gov or (866) 577-0771 if you have difficulty locating or uploading documents.

Remember, you can always contact your Program Officer directly with any questions related to your Part C grant.

Resources for a Deeper Dive