Column: The Rest of the Story on Unique Entity IDs

By Tom Johnson, publisher, Set-Aside Alert

      Over April Fools’ Day weekend, the General Services Administration implemented a substitution of the longtime “DUNS” number identifying each contractor, replacing it with new Unique Entity Identifier. The new identifier is being referred to as the “UEI” or “SAM” number.

      So far, it appears that the effort was successful. The revision has been applied throughout the Integrated Acquisition Environment managed by GSA.

      Before we get into the “rest of the story”, if you’ve missed the preliminary announcements and our news coverage of this change, GSA has assigned a new universal identifier to all entities registered in the System for Award Management (SAM). In conjunction with creation of the identifiers, GSA will now take over the registration and assignment of UEIs for all entities in SAM. This work previously was contracted out to Dun and Bradstreet for use of their proprietary nine-digit Data Universal Numbering System (DUNS), along with update processing.

What is your UEI?

      All entities registered in SAM already have been assigned new IDs. To locate your number, you must log in to SAM.gov. GSA is not sending letters or emails to registrants to tell them of their newly-assigned identifiers. The new codes are 12-character alphanumeric designators, letters being in all-caps. Unfortunately, they are much more difficult to memorize than DUNS 2+3+4 numerics so you will probably have to dig it up each time you need it.

Why does my company need it?

      You need to enter this identifier wherever you previously provided your DUNS number, e.g., on proposals, capabilities statements, invoices, e-Buy, eSRS and prime and subcontract reports to Vendor Support Center and the FSRS (FFATA Subaward Reporting System). In the latter case, you will need to use the UEI of your subcontractor on the FSRS reports, so make sure they register also.

Update your templates now

      Update your templates now so you avoid mistakenly submitting an incorrect UEI in coming submissions. And we recommend that you continue to include your DUNS number as well. There is a one-to-one correlation of DUNS to UEI initially, so adding another static datapoint on your templates should be easy to implement.

      The importance of using this new ID is exemplified by the fact that Awarding Officials and contract-writing software apps will now be using the UEI and not be checking against the DUNS number, so you are at risk at the critical, last-minute contract closing time to have no barriers in the way of a quick award.

Do you have saved searches in SAM, FPDS or entity-specific APIs?

      If you have saved searches or selections based on DUNS numbers, you will need to update them for the new UEIs. Many contractors monitor their competitors and suppliers by having saved searches in SAM’s opportunities and FPDS (Federal Procurement Data System) data to keep track of market share and win rates. These saved searches are no longer operable in the new environment if they are based on DUNS numbers, so revise them now to focus on the relevant UEIDs.

How do you register a new joint venture, operating location or subsidiary?

      Go to SAM.gov as always and set up the entity. You will not need to go to dandb.com, as that was for the DUNS. For new registrations, each entity needs its own UEI. Do not skimp and try to slide through on yours – each separate entity needs its own even if the address and other information are basically the same.

What about reporting for other agency purposes?

      UEI does not replace your taxpayer identification number (TIN), your CAGE code, or forms and reports that ask specifically for your DUNS number, especially if they are for agencies outside of GSA. And beware of old versions of reporting forms that may not reflect the update from DUNS to UEI. You’ll risk being tagged and penalized for late or erroneous reporting.

What applies outside the US?

      Similarly, if you are in an OCONUS environment (Outside the Contiguous U.S) in which another country requests your DUNS number, provide that in lieu of the UEI. Other agencies and other countries are not mandated to use the new identifiers in their own acquisition environment, only where the opportunities will be posted on and awarded via systems that comply with the Integrated Acquisition Environment. Most direct Federal agency procurements fall in that category, but not those of our friendly nation partners nor those outside the federal agency contract arena.

      At this time, one clear adoption of the identifiers is assured: federal grants. If your company or organization pursues Small Business Innovation Research (SBIR) or Defense Logistics Agency grants, you will use UEI instead of DUNS numbers. If you are an individual who has personal service contracts or operates through some other personal/individual non-company-organization basis, your TIN/EIN may still be the relevant identifier.

     Now, you know “the rest of the story”, at least for now.

More information:
Updating your address, POCs etc.: https://bit.ly/3vgzLu1
Subcontractor identifier assignments: https://bit.ly/3KDmySb
Federal Service Desk guidance: https://bit.ly/3Ee524Q
FSD interactive tool: https://bit.ly/3E5NOX6

Contact Tom at tjohnson@setasidealert.com.

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Column: The Rest of the Story on Unique Entity IDs

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