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Bye Bye DUNS, Bye Bye Old Login, Hello Begin Again I Think I'm Gonna Cry, Bye Bye My DUNS Good Bye


There goes our old DUNS. Here's something new. In fact, there are three new protocols in the works in the System for Award Management (SAM.gov), all of which significantly impact our ability to pursue and receive federal funds. 
 
The timeline for these changes began in 2018 and will continue over the next 18 months to December 2020. Please note the new requirements and check your SAM.gov registration.

DUNS
 
On July 10, the General Services Administration (GSA) posted an announcement in the Federal Register (84 FR 32916) that the Unique Entity Identifier (UEI) standard was considered final. The UEI replaces the DUNS number for all nonfederal entities.
 
Previously in 2016, the Office of Management and Budget (OMB) removed all references to DUNS in the Federal Acquisition Regulation (FAR) and in the uniform guidance; however, it kept using the DUNS number. SAM.gov also referenced and used the DUNS number as part of its registration process.
 
The DUNS number; however, will now be phased out through 2020 as nonfederal entities renew their registrations in SAM.gov. A new, non-proprietary 12-character identifier number will replace DUNS, and over the next 18 months starting in July 2019, existing SAM.gov users will automatically be assigned the new UEI at the time of registration renewal. The old DUNS number will no longer work; however, all DUNS numbers will be retained in the system for search and reference purposes.
 
While this sounds easy enough, those of us who experienced the automatic transition to SAM.gov from the former Central Contractor Registry (CCR) in July 2012, will remember challenges depending upon the operating system used. Google Chrome worked best. Internet Explorer, Safari, and Fire Fox had varying degrees of success. Simple differences such as whether or not the four-digit zip code extension was used also prevented automatic transition for some users.
 
Nonfederal entities, therefore, should make a note of the date their annual SAM.gov registration is due to renew, and monitor that process carefully to ensure successful receipt of the new UEI and completion of their renewals. Use of the DUNS would cease and all records using the DUNS would need to be updated.
 
Login.gov
 
Login.gov is an official website of the U.S. government and it is an identity management system. In an effort to increase security and deter fraud, SAM.gov entered into a partnership with Login.gov to implement a stronger authentication process for SAM.gov users.
 
After fraudulent activity was discovered in the SAM.gov database in June 2018, GSA implemented a new validation process that required a notarized letter. This process caused delays at the Federal Service Desk, and GSA subsequently transitioned to a requirement for a Login.gov user account instead.   
 
Effective last year, June 29, 2018, SAM.gov began requiring the Login.gov user account. Nonfederal entities currently registered in SAM.gov should experience an automatic migration of their roles to the new system using their same SAM.gov email address. If a different email address is desired, there will be some delay as roles are reassigned.
 
Current SAM.gov users may want to check the status of a Login.gov account, and note the credentials for their files.
 
SF 424B
 
The assurances form used in proposal submissions, Standard Form (SF) 424B is also being phased out. Nonfederal entities will agree to the federal assurances at the time of registration renewal in SAM.gov rather than in proposal submissions.
 
Nonfederal entities should continue to include the SF 424B form if it is present in application packages, but phase-out is anticipated by 2020.
 
Updates will follow as new information becomes available.
 
For More Information
 
Go to https://www.login.gov to check authentication credentials.
 
Visit www.gsa.gov/entityid to read about the unique entity identifies (UEI).
 
Refer to https://www.whitehouse.gov/wp-content/uploads/2018/09/M-18-24.pdf
for the SF 424B form phase-out


By Karen Norris, Principal, kanoco
https://kanoco.com

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