By Karen Norris, Principal, Kanoco, Consulting
https://kanoco.com
The Office of Management and Budget (OMB) and the General Services Administration (GSA) announced in July 2019 that the DUNS number would be phased out and replaced by a new Unique Entity Identifier (UEI) number by December 2020, and in October 2020 extended the transition to April 4, 2022. The incremental transition would occur as nonfederal entities would renew their registrations in the System for Award Management (SAM.gov).
In fact, there are three new protocols in the works for SAM.gov, all of which significantly impact the ability to pursue and receive federal funds. Federal agencies and nonfederal entities should note the new requirements and check SAM.gov registration renewals.
DUNS to UEI
On July 10, 2019, GSA posted an announcement in the Federal Register (84 FR 32916) that a new 12-character (alphanumeric) Unique Entity Identifier (UEI) would replace the current 9-digit DUNS number for all nonfederal entities. The new standard will require all federal agencies and nonfederal entities to create new fields in databases, financial systems, on federal, state, and local forms, and on multiple websites.
Previously in 2016, GSA and the Office of Management and Budget (OMB) removed all references to DUNS in the Federal Acquisition Regulation (FAR) and in the uniform guidance; however, the DUNS number was still in use. SAM.gov and Grants.gov also continued to use the DUNS number.
In 2019 the initial announcement identified a December 2020 target to complete the transition from DUNS to UEI through SAM.gov registration renewals; however, more time was needed, according to a GSA announcement October 26, 2020, to complete the process. The new timeline for completion is April 4, 2022, when the UEI number is scheduled to go live.
The Code of Federal Regulations (2 CFR 25) was also updated to reflect the pending change to the UEI number, final rule published in the Federal Register on August 13, 2020, effective November 12, 2020.
Nonfederal entities, therefore, should make a note of the date when their annual SAM.gov registration is due to renew, and monitor that process carefully to ensure successful receipt of the new UEI and completion of their renewals. All record fields and electronic systems using the DUNS number should be updated for the new UEI number.
Login.gov
Login.gov is an official website of the U.S. government and serves as an identity management system. In an effort to increase security and deter fraud, SAM.gov entered into a partnership with Login.gov to implement a stronger authentication process for SAM.gov users.
After fraudulent activity was discovered in the SAM.gov database in June 2018, GSA implemented a new validation process that required a notarized letter. This process caused delays at the Federal Service Desk, and GSA subsequently transitioned to a new requirement for a Login.gov user account instead.
Effective June 29, 2018, SAM.gov began requiring the Login.gov user account for more secure username and password credentials. Nonfederal entities currently registered in SAM.gov should experience an automatic migration of their roles to Login.gov using their same SAM.gov email address. Current SAM.gov users may want to check the status of a Login.gov account, and note the credentials for their files. Additionally, Grants.gov users will also need Login.gov credentials.
SF 424B
The assurances form used in proposal submissions, Standard Form (SF) 424B was also phased out, December 2020, replaced by required assurances and certifications made as nonfederal entities renewed registrations in SAM.gov.
Nonfederal entities should continue to complete the SF 424B form if it is still present in application packages. Some federal agencies have kept it in their solicitation packages.
For More Information
Visit www.gsa.gov/entityid and/or https://interact.gsa.gov/blog/government-transition-duns-number-new-unique-entity-identifier-extended for the UEI extension to April 4.
Go to https://www.login.gov to check authentication credentials, passwords, and logins.
For help with SAM.gov, registration, and UEI transition, please contact the Federal Service Desk at www.fsd.gov.
Refer to https://www.whitehouse.gov/wp-content/uploads/2018/09/M-18-24.pdf for the SF 424B form phase-out.
© 2022 Karen Norris, Kanoco Consulting
Karen Norris is nationally recognized in the grants community as a consultant and Subject Matter Expert (SME) for Kanoco Consulting - a Karen Norris Company, with offices in Maryland and Delaware. Previously, she worked for educational institutions as the grants administrator, and as managing editor at a national publishing house. Norris has served on Boards of Directors of professional associations, presented at state and national conferences, provided testimony to the Maryland General Assembly and a U.S. Senate Subcommittee about grants, and has served as a federal grant reviewer.