GSA Demystifies DUNS Replacement ID

Change can be confusing. Change can be frustrating.” No, this is not from the cover of a self-help book. This is GSA’s acknowledgment that, often, we fear change.

To combat fears about changes to the DUNS number, GSA recently released a Q&A providing some answers on the new Unique Entity ID (UEI) Standard, which is set to replace the current DUNS system in December 2020. The Q&A followed GSA’s online meeting on the topic in July, which hosted over 700 attendees. GSA answered general questions about the transition, the UEI that will be used, and how to obtain a new identifier. Let’s take a look.

As a reminder, GSA intends to complete the transition from the current DUNS numbering system to the new SAM-generated UEIs in December 2020. But the transition will actually begin sooner. As GSA explains:

There is going to be a lengthy transition period during which IAE will provide specific transition activities and cutover dates. By December 2020, the SAM-generated UEI will be the authoritative unique entity identifier in SAM.

The overarching concept will remain the same. GSA will use the UEI system in much the same way as its used the DUNS numbers. SAM will retain the hierarchy of entities for “child” and “parent” companies and for subdivisions and multiple locations within corporations, as under the DUNS system.

Here are some of the key take-aways from GSA.

Getting a UEI is basically automatic.

Many of the questions from the July meeting surrounded what steps need to be taken to ditch the DUNS number and to obtain a new UEI. GSA said that the new UEIs will be automatically generated and automatically assigned to all existing entities in SAM. But GSA also cautions that “entities may need to take action to start using the new UEI where they are currently using the DUNS,” since it is crucial for federal contractors to keep their online profiles up to date with the most recent information. GSA also explained:

The DUNS will continue to be the official identifier for entities registered in SAM until the cutover to the SAM-generated UEI. After the cutover,the primary identifier for entities registering in SAM will be the UEI. New entities registering after the cutover will not have a DUNS number associated with their registration.

And for those currently renewing their SAM registration, the renewal process should be continued as normal to maintain active status. Entities will not need to re-register or renew their registration to be assigned the UEI during the transition. New registrants will be assigned a UEI as part of their SAM registration. It explains:

When requesting a Unique Entity Identifier, the entity will provide basic data (e.g. legal entity name, doing business as name, physical address) which will be used to validate uniqueness. During the full SAM entity registration process, the entity will provide the same comprehensive data set they do today.

GSA intends to establish a notification process for previously-registered entities to find their assigned UEI, which will made available for viewing in SAM. Plus, “CAGE codes that are associated to a SAM.gov entity registration will be assigned a Unique Entity Identifier.”

How the UEI will be used on payment systems and proposals is not up to GSA.

GSA warned that the federal payment systems will likely be affected and urges contractors to “be in touch with those system owners about how any change will be implemented.” Contractors also asked when they should start using these new identifiers on proposals, invoices, etc. GSA responded that is up to the individual agencies, explaining:

GSA is working with agencies during the transition. However, agencies will develop their own policy and implementation guidance. Contact the appropriate policy officials in your agency.

What about using the UEI on proposals if assigned one prior to December 2020? Don’t start using it yet, as GSA cautioned that “there will be further instructions on when the UEI should be used for proposals and other award actions.”

DUNS remains for historical purposes.

GSA was also asked about the fate of the DUNS number, and it said that it intends to retain the DUNS for historical purposes only. The new UEI and the original DUNS numbers will remain searchable fields for historical records and “exclusions” searches, explaining:

Yes. The DUNS number tied to historical records will remain a field against which you can search. For those records which have both an assigned DUNS number and a new SAM-generated UEI, you will be able to search for the record by either identifier. This includes exclusion records

Additionally, GSA directed contractors to the Federal Register notice for formal information on the character set that will be used for UEIs and other relevant information on the new system and standards. The Q&A also addressed a number of other topics such as grants and subgrants, the transition lift for specific agencies, subrecipients unregistered in SAM, and how state and local agencies are affected.

While change is scary, perhaps the transition away from the DUNS number doesn’t have to be too terrifying. Check out the full Q&A for information on making the change a little easier and for answers to more specific questions.