The administration pushed the deadline for adopting a new identifier for non-governmental organizations receiving funds from the government, giving federal agencies and contractors another 16 months to patch and test their systems.
The government is shifting from the DUNS number—the unique identifier for every organization doing business with the government since 1962—to the Unique Entity Identifier. Agencies were originally expected to make the switch by December 2020 but have been given an extension to April 2022.
However, federal officials tell Nextgov the deadline extension will only help if agencies and organizations are able to use DUNS and UEI numbers at the same time during a testing period, which might be possible under the revised timeline.
Procurement, grants and financial reporting executives across the government were scrambling to meet the December 2020 deadline to turn off an almost 60-year standard for identifying organizations doing business with the government and switch to a brand new system introduced last year.
“This is a pretty unique business problem,” an agency official working through the transition told Nextgov. “This is not just large-scale system modernization. This is the most interdependent thing about doing business between the federal government and a non-federal entity—it’s at the heart of it.”
The DUNS, created by Dun & Bradstreet in 1962, has been the official entity verification number since it was codified in the Federal Acquisition Regulation in 1998. Since that time, every organization doing business with the government—contractors, grantees, universities, research centers, incubators, charities, etc.—has been issued a DUNS number.
The General Services Administration, which administers the program, opened the contract to new vendors in 2018. GSA awarded the new contract in March 2019 to Ernst & Young, which will administer the new ID number, including managing the transition from Dun & Bradstreet.
After the award, GSA and the Office of Management and Budget gave agencies until December 2020 to recode any systems that used DUNS—which are a lot—to accept the UEI number. After the deadline, no new DUNS numbers would be issued.
In an acknowledgement of the difficult situation, OMB announced that the deadline would be extended to April 2022.
“The Office of Management and Budget directed federal agencies to finalize their transition to using the SAM-generated unique entity identifier—unique entity ID or UEI—by April 2022,” GSA officials said in a post on Interact. “GSA will be contracting with Dun & Bradstreet to ensure full continuity of services—including DUNS number assignment, monitoring, and validation of entity uniqueness—during the extended transition period.”
Prior to OMB’s decision to extend the deadline, federal officials working with procurement and grants told Nextgov they needed more time for the transition. But, more importantly, officials said they wanted to see a parallel approach in which GSA issued DUNS and Unique Entity IDs simultaneously for a time, allowing agencies to use both in case a system isn’t able to process the new identifier.
This will now be possible, as GSA has already begun to assign UEI numbers behind the scenes, an agency spokesperson told Nextgov. The new identifiers will be made public beginning sometime in fiscal 2021, they said.
“In order for the U.S. government to maintain transparency in the award management process throughout the extended transition period, GSA will also be contracting with Dun & Bradstreet to ensure full continuity of services—including DUNS number assignment, monitoring, and validation of entity uniqueness,” the spokesperson said.
GSA has said in the past that the DUNS number isn’t going away immediately, as it is still tied to a myriad of historical records that would be useless if the numbers were just erased. But once the transition is finalized, the government will no longer issue DUNS numbers to new entities doing business with federal agencies.
The shift is more than nomenclature: DUNS consists of nine numbers, while UEI is a 12-digit alphanumeric sequence. The shift will require physically recoding and patching every system that records transactions between the government and any non-government entity.
Federal officials outside of GSA warn this could be disastrous if not done carefully, agreeing the transition could be likened to the Y2K banking crisis at the turn of the millennium, in which financial organizations’ systems and any systems touching those systems had to be recoded to include a four-digit year or risk imploding the world’s financial infrastructure.
Like the Y2K crisis, a successful transition from DUNS to UEI will require analyzing and testing every government and non-governmental system that processes contracts, grants or financial transactions and recoding them to accept the new identifier, along with the old.
The work is doable—there is no magic needed, just time, money and a fine-toothed comb—but any missed system or line of code or out-of-place comma could lead to multiple system failures.
“When government aligned around the DUNS, it created a common business key across entities, which is great,” an official told Nextgov. “But all the business operations have been built around that business key. … It’s embedded in everything.”
OMB was aware of the issue earlier this year. An April 2020 email from the federal Chief Financial Officers Council to the council’s membership noted ongoing concerns, as well as the COVID-19 pandemic.
“Based on agency input, the sessions of the UEI Working Group, and in light of agencies’ focus on COVID-19 response activities, OMB recognizes that the current due date for UEI implementation is not feasible across programs,” the email states [original emphasis kept].
Multiple big-name federal contractors have told their agency clients that they would be able to meet GSA’s original deadline, while others have said the transition will take longer. Either way, once those systems are updated they will still have to be tested in agency environments—a process that could take a year or more, especially for procurement- and grant-heavy agencies, as well as state, local and private sector systems.
The email to CFO Council members identified the working timeline for four major systems. While all four systems were expected to be patched by the December 2020 deadline, testing those systems for all federal agencies that use them would go well beyond the initial schedule.
- SAP: Patch ready by April 2020; Testing window from April 2020 to October 2021.
- CGI Momentum: Patch ready by June 2020; Testing window from June 2020 to December 2021.
- Oracle: Patch ready by December 2020; Testing window from December 2020 to June 2022.
- Grants.gov: Patch ready by December 2020; Testing window from December 2020 to June 2022.