Can a covered facility have contractors or lawyers fill out their SVA?
A contractor or consultant (who may in fact be a lawyer) hired by the covered (high risk) facility may act as a Preparer (see CSAT User Registration Manual, page 33). Due to the very specific information about the facility that is required by the SVA, the individual designated as the facility’s Preparer should be knowledgeable about the facility. The Preparer is authorized to enter the data into the CSAT system and to send it to the Submitter via the system. As with Top Screens, a consultant may not be a Submitter of an SVA; the Submitter should be an officer or other employee of the company designated by an officer who is domiciled in the United States. See CSAT User Registration Manual, page 19.
