What’s DUNS (Still) Got to Do with It?
One of the most common questions our instructors have been receiving in our classes in 2015 is, “Does my organization still need a DUNS number?” The short answer is yes. My colleague, Shane Jernigan, summed this issue up nicely in our May eClips – so nicely that I want to share it again:
The Office of Management and Budget (OMB) published the joint interim final rule implementing 2 CFR 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). In the joint interim final rule, OMB made dozens of technical and editorial changes to the Uniform Guidance. OMB made these edits to correct typographical errors and to provide additional clarification regarding the new requirements.
One editorial correction potentially signals a dramatic change for the grants community — OMB removed all references to the Data Universal Numbering System (DUNS) Number. In place of the DUNS Number, the joint interim final rule refers to a “unique entity identifier,” defined at 2 CFR 25.315 as “the identifier required for SAM (System of Award Management) registration to uniquely identify business entities.”
The change in terminology has created some confusion. Currently, SAM.gov still identifies the DUNS Number as the required unique identifier that all non-Federal entities must have in order to apply for, receive, and report on a Federal award. Therefore, all non-Federal entities are required to continue using the DUNS Number for all grant-related documents.
OMB’s removal of all specific reference to the DUNS Number may be foreshadowing a change to grants management. Recently, leading trade associations have begun a “Dump DUNS” movement. This campaign is designed to encourage OMB to stop requiring the use of the DUNS Number and develop new data elements. Supporters of this movement believe the use of the proprietary DUNS number, owned by Dun & Bradstreet, Inc., restricts open and free data and limits transparency.
Due to the technical change in the interim joint final rule, the term “unique entity number” will begin to appear on grants-related documents. Non-Federal entities should not confuse this term for the unique Federal Award Identification Number (FAIN), which applies to the specific award. Until OMB provides further guidance, non-Federal entities should continue to use their DUNS Number for the unique entity number requirement.
Of course, Dun & Bradstreet is still working to maintain its footprint in government acquisition and grants systems. For example, Dun & Bradstreet was a sponsor of last week’s DATA Summit. It’s also worth noting that the Government Accountability Office (GAO) 2012 recommendation to the General Services Administration “[t]o ensure that government agencies have improved access to information needed to effectively fulfill their missions, the Administrator of GSA should initiate discussions with Dun & Bradstreet on ways to reduce current restrictions on the use of DUNS numbers,” remains open. So at least for now, it seems that the change in the Uniform Guidance requiring a “unique entity identifier” is just an initial step in breaking up this monopoly.