Earlier this month, the GSA announced a new Unique Entity Identifier Standard for Federal awards management. The new standard will go into effect December 2020. It will replace the current DUNS number system as the official identifier for all businesses contracting with the U.S. Federal Government. This should make registering to do business with the federal government a little easier, but the proof will be in the roll-out.
The GSA’s Office of Systems Management, Integrated Award Environment (IAE), published an official notice of this new “Unique Entity ID Standard for Awards Management” in the Federal Register on July 10, 2019. The new standard will be considered “final” on that date. The GSA plans to have the new system in place by December of 2020.
GSA’s notice announces:
[T]he U.S. government is moving to a new unique entity identifier for federal awards management, including, but not limited to, contracts, grants, and cooperative agreements, which will ultimately become the primary key to identify entities throughout the federal awarding lifecycle, in SAM.gov, other IAE systems, on required forms, and in downstream government systems.
GSA explains, “IAE systems will be transitioning from the DUNS® to a SAM-generated Unique Entity ID (UEI),” the new identification standard developed by an inter-agency working group. The “new entity identifier will be the authoritative identifier once the transition is complete,” and the “DUNS® will be phased out as the entity identifier for entity record[s] within SAM.” GSA’s website further details this transition-plan, including specifics of GSA’s plan to phase out the current Dun & Bradstreet Data Universal Numbering System (DUNS®) over the next 18 months.
The new, non-proprietary identifier for federal awards management aims to resolve government concerns with the previous system. The DUNS system required contractors to register for a unique nine-digit identification number for each business location. And this DUNS data was used to keep track of government funding. Because this specific proprietary data standard inevitably limited the usability and accessibility of such data, the system raised many issues with the federal contracting principle of an open and transparent government. It also granted Dun & Bradstreet a monopoly on data requiring DUNS classification.
As such, the GSA, DoD, and NASA all proposed to eliminate DUNS requirements over the last few years. And in 2016, the FAR and Title 2 of the C.F.R. were revised to remove the proprietary references to Dun & Bradstreet and the DUNS numbering system as the unique entity identifier. Because this “allowed the government to decouple the required unique identifier from the supporting entity validation services,” the GSA’s new system can now be implemented.
The technical specifications for the new system are published in the Federal Register to give interfacing systems time to prepare for the change. The GSA will also be hosting a virtual meeting to provide more information on the new standard to current and potential federal awardees and the public on July 25, 2019, at 1 p.m. Eastern Standard Time. Anyone interested in participating must register through the GSA website. And additional information on the new standard, its implementation, and the Unique Entity ID specifics, can be found on the GSA website as well.
Questions about this post? Or need help with a government contracting legal issue? Email us or give us a call at 785-200-8919.