It’s been ten years in the making, so the transition to Unique Entity ID (UEI) earlier in 2022 was no surprise, but industry and the federal government alike have been dealing with “unforeseen” issues. Well-intentioned to create more open competition, this change has in some instances, actually hindered business and payments from continuing. In this article, The Pulse breaks down what happened and what went (or is still going) wrong.
What is a UEI?
UEI is a 12-character alphanumeric value that has completely replaced the Data Universal Number System (DUNS) Number. The switch from the DUNS number to the UEI went into effect on April 4, 2022. As a direct result of this change, the DUNS number is no longer valid for federal award identification.
UEI verifies an organization’s name and address; it is a non-proprietary identifier that allows businesses to receive contracts or assistance directly from the federal government. UEIs ensure money is going to credible entities in a timely manner and reported correctly. This change is now reflected in FAR subpart 4.6.
What is the Background?
For context, Dun & Bradstreet has been providing identification and validation services of federal contractors to the government since 1978, and DUNS numbers have been required by the FAR since 1998.
This is a massive change that has taken over ten years to come to fruition…
This transition from DUNS numbers to UEIs was required by the Office of Management and Budget (OMB) as part of a technology modernization project started in 2012. The first major step towards this goal was removing the proprietary references from 2 CFR in 2014.
Two years later OMB created a working group to assess business needs for entity validation and verification requirements, giving the project momentum.
In October 2020, OMB announced that federal agencies had until April 2022 to finalize the transition to UEIs, giving agencies 18 months to prepare. There was also a six-month parallel test so agencies could experiment with compatibility between UEIs and their existing IT systems.
Each federal agency was responsible for updating its award and payment processes and systems. Agencies often worked together to determine what would need to be updated and shared best practices on how to do so.
How is the Change Happening?
UEIs are automatically assigned to entities when they request one or register on SAM.gov. Now that the transition has happened, no additional work is required from contractors. This applies to both active SAM.gov registrations and newly registered entities. Businesses can find their UEI through their Workspace on SAM.gov. When businesses need to change their name or address, they can do so through SAM.gov instead of Dun & Bradstreet, as was the process with DUNS Numbers.
Even though GSA is assigning UEIs, third-party verification is still needed to ensure the information provided is accurate and consistent. Ernst & Young was awarded a five-year, $41.7 million contract to provide services to validate entities’ identities. Unlike with the DUNS number, entities do not have to create an account with Ernst & Young.
Entities can get a UEI if a business does not have or require an entity registration in SAM.gov. This may apply to subcontractors, businesses that accept government purchase cards, or if the prime is required to report on subcontracting dollars.
UEIs provide the same corporate information that the DUNS numbers did. They also do not expire, even if the entity’s SAM registration does. This applies to all Integrated Award Environment (IAE) systems: SAM.gov, eSRS, FSRS, FPDS, FAPIIS, and CPARS. UEIs are not considered Personally Identifiable Information (PII) by the federal government. This means that a UEI alone is not enough to connect to a specific entity, although UEIs are still sensitive information.
What is the Impact?
Government Managed: UEI is managed, granted, and owned by the government, whereas the DUNS number was generated and controlled by Dun & Bradstreet, a private company. No longer having to go through a third party to get an identifier or assistance simplifies the entity registration process (in theory) and (is supposed to) make it easier for entities to work with the federal government. This contract also reduces duplicative contracts throughout the government because each agency does not have to contract for this service.
Cost Savings: The government paid Duns & Bradstreet $891.1M in total while it wielded the DUNS Number. Contractors received their DUNS number for free, but it was costly to the government. Internally managing UEIs will (hopefully) cut costs for the Government. UEIs also provide predictability for the cost of entity validation services. Obtaining a DUNS number is free and can take up to 30 days, although companies can pay $229 to receive theirs in only five days. Being able to speed up this process gives companies a leg up as they are able to access solicitation information and the ability to submit proposals ahead of companies who do not pay the fee. Conversely, UEIs are free to register and maintain in SAM.gov.
Increase in Data Transparency: The transition will also lead to more data transparency. Government data websites such as USASpending.gov will be more accurate and true-to-date since GSA now holds all of the entity data, instead of relying on Dun & Bradstreet to provide it.
Increased Competition: UEIs allow for more competition in entity validation services. The UEI system is vendor independent, so the government can now more freely compete and award contracts to execute the unique entity validation process. Instead of Dun & Bradstreet providing the identifier and validating the entities, SAM provides the identifier and only has to outsource the validation services. This transition means that the government can compete the validation services as that process is now separate from the identifier itself. When the Government used UEIs, this work had to be done by Dun & Bradstreet since it was the one issuing the identifier, now it does not matter if Dun & Bradstreet, Ernst & Young, or any other company provides the validation services. Even if a different entity validation service is chosen in the future, the identifier will not have to change. Over time, this allows for more competition.
What Challenges Have Arisen?
As with any major electronic system transition, the switch from DUNs to UEIs has been a bumpy transition. Most of the issues stem from verification and validation delays, but some are more deep-cutting. All pose threats to businesses’ contract proposals, execution of work, and payments. The cited reason for these problems is new entities in the validation process, including those who are not required to register.
Some businesses have been removed entirely from the GSA online system as a result of the switch, but one of the most common issues occurs when the information in SAM.gov is not accurate. If a business does not match the system-generated legal name and address for its SAM registration, it will have to submit entity validation documentation of a particular kind and timeliness. This applies to new entities and existing SAM-registered entities, and this problem has arisen because data rights prevent SAM.gov from using previously validated data.
This can cause problems for:
- Businesses that have sustained name or address changes, mergers, or similar transactions
- Businesses with multiple SAM-registered physical addresses
- Foreign businesses
- Businesses whose address documentation is more than five years old
- Businesses with unregistered operating names
The problematic transition has caught the eye of Congress as well. The House Committee on Oversight and Reform submitted a letter to the General Services Administration (GSA) in July outlining how some businesses are being stalled by the transition, and how it is impacting their ability to pay their workers. The letter details how if a business does not have access to its UEI, and therefore the systems that utilize UEIs, it cannot do business or gain new business with the federal government – potentially resulting in loss of income.
There have been instances where small businesses are owed $200,000 and $400,000 but cannot be paid due to problems with their UEI. The same company waiting on $200,000 also missed out on a task order because the contracting agency wasn’t able to place the order due to the UEI problem.
Another UEI complication has paused humanitarian projects in Turkey and Jordan because the local sub-grantees don’t have UEIs yet. They are unable to receive the money and begin the work despite already being selected for the grant. Additionally, companies cannot access, review, or appeal their CPARS ratings without their UEI.
There are also some humorous, less harmful issues occurring. One example is the UEI random number generator generating curse words within the UEIs. Approximately 10,000 UEI numbers had to be changed because they contained inappropriate words.
Businesses seeking help are often met with links to unhelpful FAQ pages or spend hours on phone calls with customer service representatives who are ultimately unable to solve the problem. Some support tickets are over twelve weeks old without resolution.
What Solutions are Being Offered?
Individual federal agencies have been offering alternate solutions and providing guidance on how to manage the delays. In some circumstances, agencies can use alternative methods of procurement or payment processes. Some agencies have accepted GSA help desk ticket numbers from contractors as confirmation of an attempt to revalidate or re-register to allow payments to continue while the issue gets resolved.
The Department of Defense’s (DOD) Office of Defense Pricing and Contracting has approved a six-week extension for the service and defense agencies beginning September 8, five months after the transition. During this period, contractors are not required to have an active SAM registration. This is acceptable for all contractors as long as they can prove they have at least attempted to get their UEI or SAM registration. Entities will need to have their registration sorted out before 30 days post-award or the first invoice. This extension is derived from FAR 52.204-7 and can be applied to existing solicitations that expect to make an award before the end of October. The contracting agency will also escalate awardees’ FSD tickets with SAM to resolve the issue faster.
DOD advised companies to use this exception sparingly because not having an active SAM registration will eventually impact contract performance, administration, receipt, and invoicing processes. Taking advantage of this exception has its own requirements, including providing the ticket number submitted to the Federal Service Desk (FSD); ensuring an alternate submission is provided for Procurement Integrated Enterprise Environment (PIEE) solicitations; closely monitoring the SAM registration process post-award, and only reporting the award to FPDS once the contractor is registered in SAM.
GSA is also using the extension approach to reduce problems associated with the UEI transition. The submission deadline for the Polaris Small Business and Women-Owned Small Business pools has been extended for the fifth time since May 2022. Bidders have experienced difficulties submitting information because of complications acquiring a UEI. Previous extensions of this huge governmentwide IT vehicle were for difficulties with SAM.gov as well.
In anticipation of initial complications, GSA planned for extra staffing support for the beginning of the transition. GSA has held several IAE Stakeholder Forums addressing the main questions and problems entities are facing. GSA recently announced several improvements as well. These are:
- Step-by-step instructions for selecting an entity from search results;
- A feature to request all entity data at once;
- Improved help articles on FSD.gov;
- A list of what information and documentation will be required is available at the start of the process;
- Ability to state if and where the user wants to use one document for multiple pieces of entity information; and
- Clear confirmation that documents were submitted
These changes are intended to simplify ticket requests and improve user experience. It takes approximately fourteen days to register an entity if all documentation is correct, and GSA is working to decrease this timeframe. There has been no indication of a solution being implemented that is intended to rectify the cause of the problems, only to facilitate solving them.
The change from DUNS to UEIs was a long process that was tested and discussed for over half a decade. The federal government ultimately decided this switch was beneficial to businesses because it would simplify the acquisition process, be more cost-effective, and create more competition. However, entities are dealing with system failures and long remediation processes. As time goes on, the kinks will (hopefully) be worked out, but there’s no telling as of when.