For years, SAM.gov registration has been viewed as an administrative requirement—a routine process used to verify institutional information before receiving federal funds. The U.S. General Services Administration's proposed changes would transform registration into something much more consequential: a broad institutional certification requiring Authorized Organizational Representatives (AORs) to attest that institutional policies, programs, and practices comply with expanding federal requirements, evolving legal interpretations, and applicable executive orders. As the scope of these certifications grows, so does the governance, documentation, and cross-functional coordination needed to support accurate and defensible institutional representations.
While still proposed, these changes signal a broader shift in federal oversight, from verifying organizational information to requiring institutions to stand behind increasingly comprehensive representations about compliance. That shift raises important questions about institutional readiness, executive oversight, and the processes used to review, validate, and approve federal certifications before they are submitted. Becca van Lieshout, GPC and Teri Zuzevich, experts from the Ellucian Grants Services team examine potential impacts of the changes proposed to go into effect in 2026.
What's changing at SAM.gov?
At its core, SAM.gov registration is proposed to shift from routine paperwork needed for administrative verification to a broader institutional certification that extends beyond most current institutional oversight and governance policies.
Historically, AORs primarily confirm organizational information such as institutional identity, contact information, leadership personnel, and the college's unique entity identifier (UEI) in order to maintain an active registration in SAM.gov. Under the proposed changes, the scope expands significantly from confirmation of information to institutional certification. In addition to verifying organizational information, AORs would be required to certify compliance with a broader set of federal requirements, including those tied to recent executive orders and related policy guidance. The proposed certifications address several areas of federal policy, including civil rights compliance, immigration-related attestations, and other policy frameworks established through recent executive actions.
If finalized, these changes:
- Expand institutional certifications beyond organizational information to include broader representations regarding institutional compliance.
- Increase the importance of documented governance and internal review before certifications are finalized.
- Create greater institutional and personal exposure if certifications cannot be supported through policies, documentation, and operational practices.
- Continue the federal trend toward integrating organizational certifications into broader oversight and accountability activities.
This means institutional certifications may require broader governance, stronger documentation, and greater cross-functional coordination than many institutions have traditionally applied to maintaining an active SAM.gov registration.
Why Proposed SAM.gov Changes Matter for Institutional Leaders
While these proposed changes focus on institutional certifications, their implications extend well beyond the registration process, affecting access to all forms of federal funds, to include federal financial aid, formula funds, and institutional aid.
The proposed certifications require institutions to stand behind broader representations regarding compliance, governance, and organizational practices. As a result, what has traditionally been an administrative responsibility may increasingly require coordinated review across legal, finance, sponsored programs, human resources, compliance, and executive leadership to ensure institutional representations are supported by documented policies, practices, and governance.
This signals a broader shift toward integrated, evidence-based oversight, where federal agencies increasingly expect alignment between what institutions certify, what they do, and what they can demonstrate through documentation.
What Institutions Can Assess Now
Although these changes remain proposed, they raise important governance questions that institutions can begin evaluating today. Because the certifications extend beyond traditional registration information, leaders should assess whether existing review, documentation, and approval processes are sufficient to support broader institutional representations before they are submitted.
Strategic Questions for Leadership
- Is the institution's current certification process supported by appropriate legal, compliance, and executive review?
- Does the individual responsible for SAM.gov registration have access to the information needed to certify institutional representations with confidence?
- Are institutional policies, documentation, and governance processes sufficient to support certifications if they are later questioned by federal agencies?
What Institutions Should Watch as the Proposal Advances
Institutions should monitor the progress of the proposed rule through the federal rulemaking process, paying close attention to any changes made before the requirements are finalized. Particular attention should be given to the final certification language, implementation timelines, and any guidance clarifying who may certify on behalf of an institution and what documentation is expected to support those certifications.
Regardless of the final outcome, the proposal signals that institutional certifications may become a more significant component of federal funding oversight. Leaders who establish clear governance, documentation, and review processes today will be better positioned to respond to changing requirements.
How Ellucian can help institutions prepare for evolving requirements
As federal requirements evolve, institutions need more than technology alone. They need connected systems, trusted data, and experienced partners who understand the complexity of higher education and the operational demands of federal compliance.
Purpose-Built for Higher Education, Ellucian helps institutions modernize administrative operations, strengthen governance, and improve visibility across finance, human resources, sponsored programs, and student systems. By connecting data and processes across the institution, Ellucian helps leaders establish more consistent documentation, support informed decision-making, and respond with greater confidence as regulatory requirements evolve.
Whether preparing for proposed certification changes or adapting to future federal requirements, Ellucian's technology solutions and professional services help institutions build the operational resilience needed to navigate an increasingly complex regulatory environment.
Ellucian Grants Services – Helping institutions find, secure, and manage grants to advance institutional and student success. For more information, request a Services Consultation.
Learn more about the proposed changes with our Executive Brief.
