DUNS Number Transition Delayed to an Unspecified Date

Jerry Ashworth
June 9, 2020 at 12:27:40 ET
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Well, so much for that plan.

Currently, to submit an application for a federal award, a nonfederal entity must be registered on Grants.gov — which includes obtaining a Dun & Bradstreet (D&B) DUNS number, and identifying an electronic business point of contact and an authorized organization representative — and must register with SAM.gov. The grants community had been expecting and preparing for the General Services Administration (GSA) Integrated Award Environment (IAE) to switch in December 2020 to a new federal, nonproprietary unique entity identifier (UEI) for nonfederal entities, replacing the current requirement for them to obtain a DUNS number as the UEI to apply for federal grants, cooperative agreements and contracts.

The transition date is now apparently up in the air. On its website, the IAE now states, quite briefly, that it “has shifted the UEI transition date from December 2020 to a future, to-be-determined date.” Along those lines, new UEIs will be automatically assigned to entities registered in SAM “at a future date.” Grants.gov also has changed its webpage discussing planned UEI updates in grant application forms to read that the DUNS number will be replaced “at some point,” while its timeline chart uses the acronym “TBD” (i.e., to be determined).

So goes another event in 2020 that didn’t quite go according to plan, and it’s only June.

As for some background as to why the DUNS number will eventually be replaced, when OMB issued the uniform guidance, it removed references to the DUNS number and instead used the term “unique entity identifier” (§200.210(a)). Despite this, federal agencies have continued to require the DUNS number as the UEI in their solicitations for federal funding. In recent years, however, several organizations have criticized D&B’s monopoly on the federal entity identification and validation market for grant recipients and contractors. GSA planned to transition from D&B after it picked Ernst & Young in March 2019 as its entity validation partner to come up with a new method of identifying contractors and grant recipients and to develop a government-owned identifier.

Until the new transition date is set, entities will continue to register in SAM.gov using the DUNS number. So far, GSA has published updated technical specifications that include the new SAM-generated UEIs for interfacing systems. GSA also will assign new SAM-generated UEIs for all entity registrations, contract opportunities, award reporting, subcontract reporting and past performance reporting. GSA will develop an interface to the new entity validation service provided to determine entity uniqueness, and will communicate information about any upcoming changes to stakeholders. Once IAE actually transitions all SAM-generated UEIs as the official identifiers, existing DUNS numbers will still be retained for historical purposes. Entities will not be required to reenter registration data.

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