GSA’s Big Changes in 2020, Part 4: DUNS to UEI

Merle M. DeLancey Jr.

In addition to Federal Supply Schedule consolidation, GSA is replacing the official identifier federal government contractors use. Specifically, GSA is transitioning from and will stop using the Dun & Bradstreet (“D&B”) proprietary system for verification and validation of entities registering to do business with the federal government. Effective December 2020, GSA intends to have transitioned all government systems away from using D&B Data Universal Numbering System numbers (“DUNS”) and instead using new Unique Entity Identifiers (“UEI”). The UEI is a new, nonproprietary identifier that will be assigned through GSA’s System for Award Management (“SAM”) registration process.

Since as early as the 1960s, the federal government has contracted with D&B to provide DUNS numbers to companies seeking to contract with the federal government. Just like a CAGE (Commercial and Government Entity) code, an entity seeking to contract with the government must first contact D&B and obtain a DUNS number. A DUNS number is a unique nine-digit identifier for each entity performing or seeking to perform federal government contracts. Only after obtaining a DUNS number can a company then register in SAM. If a company needs to change its legal business name or physical address, it is must make such changes through D&B. Only after D&B updated a contractor’s DUNS record and made the data available to SAM could a contractor update its SAM registration.

This government’s reliance on a system owned by a private entity is unique. It also is surprising given that the D&B proprietary DUNS system served as the sole entry way for companies to be able to do business with the federal government. Regardless, for many years, D&B received sole source contracts from GSA. In December 2014, the government began moving away from the DUNS system by removing references to DUNS numbers from federal regulations. In October 2016, the Federal Acquisition Regulation (“FAR”) was amended to replace references to DUNS numbers with UEIs. After seeking stakeholder input and conducting a procurement, in March 2019, GSA awarded a contract to Ernst & Young (“E&Y) to process and assign UEIs to entities in lieu of DUNS numbers.

Starting in December 2020, GSA hopes to have completed implementation of a streamlined request and management process for UEIs. An entity will be able to go to SAM to:

      • request a UEI and register to do business with the government;
      • update or change its legal business name or physical address associated with the UEI; and
      • contact customer support for all UEI and entity registration issues.

Existing SAM registrants will be automatically assigned a UEI and will not be required to re-enter any of their existing data in SAM.gov (currently beta.Sam.gov). A contractor’s existing information in SAM—registration, core data, assertions, representations and certifications, points of contacts, etc.—will not change. Existing DUNS numbers will be retained for search and reference purposes. GSA intends to implement a notification process so entities registered in SAM can find their new assigned UEIs. UEIs will be assigned to active and inactive entity registrations in SAM.

New SAM registrants will be assigned a UEI as part of their initial registration. When requesting a UEI, an entity will provide basic data (e.g., legal entity name, doing business as name, physical address) which E&Y will use to validate the entity’s uniqueness.

As with DUNS numbers, there will be a UEI hierarchy so that the UEIs for a parent corporation and its subsidiaries will continue to be related. The UEI format, however, will not be the same as the DUNS number format. UEIs will be twelve characters using both alpha and numeric characters. DUNS numbers are nine numeric characters.

This new format means all existing government systems that rely on DUNS numbers will require reprograming to recognize the UEI structure. Such reprogramming presents the highest risk to UEI implementation. Agency systems will be transitioned throughout 2020 with an estimated completion in December 2020. Transition almost assuredly will involve some disruption as some agencies will need to access DUNS numbers, while other agencies have already transitioned to UEIs. There is nothing contractors can do to avoid potential disruption, but at least now they understand the cause and can avoid or lessen resulting panic attacks.