NAVREF recently submitted comments in response to the General Services Administration’s proposed revisions to the System for Award Management (SAM) Registration Requirements for Financial Assistance Recipients (OMB Control No. 3090-0290; Docket No. 2026-0001; Sequence No. 2). The notice was published in the Federal Register on January 28, 2026, with comments due March 30, 2026.

In its letter, NAVREF raised concerns that the proposal could create significant legal uncertainty and administrative burden for VA-affiliated nonprofit research and education corporations (NPCs), which rely on efficient and predictable grant processes to support clinical trials, research infrastructure, and workforce capacity. NAVREF also emphasized that unclear certification language, particularly around diversity, equity, and inclusion activities, could create confusion for organizations operating in complex research partnerships and potentially discourage participation in federally supported research.

NAVREF urged the General Services Administration to ensure that any certification requirements are clearly defined, narrowly tailored, and aligned with existing statutory and regulatory frameworks, so that they do not undermine the collaborative research infrastructure that supports better care and better outcomes for Veterans.