Federal Government Switches from DUNS No. to Unique Entity Identifier

The federal government has now completed its transition from requiring nonfederal entities applying for financial assistance and contracts to register and obtain a Dun and Bradstreet Universal Numbering System (DUNS) number prior to applying for an award, and, as such, now is requiring them to register with SAM.gov to receive a unique entity identifier (UEI).

The General Services Administration (GSA) Integrated Award Environment (IAE) has been preparing for this transition since 2019. It had originally planned to switch in December 2020 to the new federal, nonproprietary UEI. However, the transition completion date was delayed to April 4, 2022. During this period, Grants.gov updated its online grant forms to enable the use of a UEI, which is a 12-character, alphanumeric value managed and owned by the government and used to identify unique entities.

IAE is a governmentwide initiative administered by GSA to manage the suite of systems that are a part of the federal awards lifecycle. Through IAE, other federal systems ― including the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS.gov) and the Federal Awardee Performance and Integrity Information System (FAPIIS.gov) ― now will accept the new SAM.gov UEI.

“This transition allows the government to streamline the entity identification and validation process, making it easier and less burdensome for entities to do business with the federal government,” according to GSA.

Registration Information

When registering with SAM.gov to obtain a UEI, known as the SAM.gov UEI, entities will still be required to provide information about the organization — such as an eBusiness Point of Contact, a nine-digit Marketing Partner Identification Number (MPIN); a Commercial and Government Entity Code (CAGE Code); and a six-digit North American Industry Classification System (NAICS) Code — as well as sign assertations, representations and certifications. If an entity was previously registered with SAM.gov, it will not need to reenter this data. Once assigned, the UEI number will never expire; however, entity registrations do expire annually and require annual renewal. An entity’s expiration date is listed in its entity record in SAM.gov.

When the Office of Management and Budget (OMB) issued the uniform guidance in 2013, it removed references to the DUNS number within former grant guidance and instead used the term “unique entity identifier” (§200.211(b)). Despite this new terminology, federal agencies had continued to require the DUNS number as the standard UEI in their solicitations for federal funding. In recent years, however, several organizations criticized D&B’s monopoly over the federal entity identification and validation market for grant recipients and contractors. GSA 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.

In light of the transition to the new SAM.gov UEI, entities no longer are required to obtain a DUNS number to register with SAM.gov and Grants.gov. Over the last year, entities already registered with SAM.gov were assigned a SAM-generated UEI. For entities that had multiple DUNS numbers, SAM.gov designated new UEIs for each of those DUNS numbers. Entities registered with SAM.gov can make any updates to their legal business name and physical address associated with their UEI(s).

Federal agencies, as directed by OMB at 2 C.F.R. Part 25, now will require an entity’s SAM.gov UEI as its official identifier, and will populate the recipient’s UEI on a notice of award. Agencies are now using forms that refer to the SAM.gov UEI. For example, the National Institutes of Health posts new funding opportunity announcements notifying applicants that they must use the FORMS-G application forms package (they previously used the FORMS-F package prior to Jan. 25), which requires them to have a UEI at the time of application submission.

Subrecipient Requirements

Subrecipients are able to request a UEI in SAM.gov, but they are not required to register with the system. Subrecipients that previously used their DUNS number for reporting now must only use their UEI for reporting. When requesting a UEI from SAM.gov, subrecipients need only submit minimal information about the entity.

In addition, entities will no longer be able to search entity registrations and whether they are on the list of excluded parties at SAM.gov using a DUNS number, as this field has been removed. Entities must use the UEI to conduct these types of searches, or search by other fields such as entity name or CAGE Code.

All grant or cooperative agreement applications submitted to federal agencies now must use version 4 of the SF-424 form, which contains the UEI number in place of the DUNS, and is available at Grants.gov. Agencies will no longer accept applications submitted using the SF-424 version 3 (or earlier versions) containing a field for entering a DUNS number.

For More Information

A Frequently Asked Questions document about the transition is available at https://tinyurl.com/skkat4e5.

A quick start guide for entities seeking a UEI without registering with SAM.gov is available at https://tinyurl.com/3xmhxxua.