DUNS Numbers May Soon be Replaced

For the past few days, we've been posting articles on FAR's fiscal year end regulation dump - prompted, no doubt, by someone's performance evaluation and bonus prospects (yes, Feds do get bonuses). So far, we've discussed the new regulations that cap compensation levels for contractor employees, the prohibition from taking reprisal action against any employee who may want to discuss or disclose their compensation, and prohibitions on contracting with tax deadbeats and felons. Today we will be discussing new regulations that may foretell a change in use of DUNS numbers - a unique nine digit identification number for each physical location of a business and a requirement for registering in SAM (System for Award Management).

Currently, FAR uses a proprietary standard or numbering system to identify contractors - the Data Universal Numbering System (DUNS) number from Dun and Bradstreet. The new regulations eliminates all references to DUNS, the proprietary name, to a generic description, "unique entity identifier" or soon to be referred to as the UEI.

Soon, the Government will embark on a process of exploring potential alternatives to the existing entity numbering systems - something that is not proprietary like the DUNS number. Although the Government is not currently in a position to move away from use of the DUNS number in the short term, elimination of regulatory references to the DUNS number will provide opportunities for future competition that can reduce costs to taxpayers. The current requirement limits competition by using a proprietary number and organization to meet the identification need as well as the need for other business information associated with that number.

 The new regulation includes a definition of "unique entity identifier" as follows:

Unique entity identifier means a number or other identifier used to identify a specific commercial, nonprofit, or Government entity. See www.sam.gov for the designated entity for establishing unique entity identifiers.

Right now, that designated entity is Dun and Bradstreet and its DUNS number. That could change and if it does, look for a lot of confusion during the transition.