Confusion Abounds Related to Unique Entity Identifier

January 16, 2015 | By Jerry Ashworth | Post a Comment

hello-my-name-is-1428915-mOne of the key technical corrections that the Office of Management and Budget and the Council on Financial Assistance Reform made in the revised uniform guidance was to remove references to the Dun and Bradstreet (D&B) Data Universal Numbering System (DUNS) and replace them with the term “unique entity identifier.” Therefore, they removed §200.32, Data Universal Numbering System (DUNS) number, and reserved the citation. OMB said that this change was “consistent with administration priorities to technically refine existing regulations,” adding that “the specific standard for this unique entity identifier will be in accordance with the requirements of the System for Award Management (SAM.gov).”

Well, that got us to wondering. What if we were nonfederal entity applying for a new grant, we would be asking what exactly is a “unique entity identifier” and how exactly do we obtain such? We contacted the staff at SAM.gov to ask those question. It appears they were just as perplexed as we were. Our initial contact person with the Federal Support Desk at SAM.gov didn’t know what a “unique entity identifier” was, and wasn’t even aware of any changes to the DUNS number. SAM.gov has “escalated” this issue for review.

This makes me wonder if the federal government has gotten the cart before the horse on this issue. It seems that the framework for this unique entity identifier should have been established first before going ahead and making it a requirement in the uniform guidance. I have witnessed at conferences that I’ve attended that there is a certain level of opposition to the DUNS number, but this sudden switch like this could only cause more headaches. OMB allowed for a procurement grace period under the revised guidance. Perhaps a similar grace period to switch from DUNS numbers to unique entity identifiers may have also been included.

Stay tuned. There may be more to follow on this topic.

Are you just as confused about this new unique entity identifier? Let us know.

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