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Entity Validation Services Frequently Asked Questions (FAQs)

1. What is a “Unique Entity Identifier” and Why is it Important?

The term “Unique Entity Identifier” refers to a numeric or alpha-numeric identifier used to identify a specific commercial, nonprofit, or government entity.  Unique identification is critical to ensure Federal dollars are awarded to responsible parties, awardees are paid in a timely manner, and awards are appropriately recorded and reported.  

The Unique Entity Identifier in the System for Award Management (SAM) is currently the Data Universal Number System (DUNS®) number with which entities register . The unique entity identifier is tied in SAM to the legal Entity name, ‘doing business as’ name, and the physical address that corresponds to it. Entities awarded Federal procurement and grants actions, with limited exceptions, are required to register in SAM. The information from SAM is used throughout the government, to include all aspects of the procurement and financial assistance processes.

The government will be transitioning away from the DUNS numbering system to a new government owned unique entity identifier (UEI). The new SAM Managed Identifier (SAMMI), will be used within SAM and the Integrated Award Environment (IAE) as a primary key to identity every existing and new entity within SAM.gov. IAE recognizes that a change to any new unique entity identifier will require a significant transition in IAE and downstream systems. To enable a successful transition to the SAMMI while minimizing the impact to Government operation, IAE has planned for an extensive transition period and anticipates transition to the new UEI be completed by 2020.

 

2. All SAM.gov registrants (contracts and grants) must provide an Employer Identification Number (EIN) or a Social Security Number (SSN) when registering in SAM. Why is a new unique entity identifier needed in SAM?

 

In accordance with procurement and federal assistance regulations, the government requires a public-facing, unique entity identifier for both domestic and international entities be available for use in government-wide systems.  Entity Validation Services involves the creation or assignment of that unique entity identifier (UEI) necessary to identify newly registering entities, entities updating their registration, all existing active entity registrations, and active “firm” exclusions in SAM. Privacy considerations preclude the Taxpayer Identification Number (TIN) -- whether it is an Employer Identification Number (EIN), or in limited circumstances, the Social Security Number (SSN) from being used as the public facing unique entity identifier. Further, only entities which are located in the U.S. and its outlying areas, or pay U.S. taxes, have a TIN. After analysis of existing government UEIs, IAE has determined that the best and most complete solution is to utilize this SAM managed identifier (SAMMI) system for identifying and managing entities within SAM and other IAE systems.

 

3. What was the process for exploring alternatives and how was industry engaged throughout the process?

Throughout the Federal Government, there are numerous other entity identifiers that serve separate purposes. The Government committed to transparently exploring alternatives to the Dun & Bradstreet (D&B) DUNS number for uniquely identifying entities receiving federal funds and has considered any reasonable alternative that satisfies the requirements for Entity Identification and Validation services. Government representatives for both the acquisition and federal assistance environments were engaged in evaluating the required business process outcomes. GSA issued two requests for information (RFIs) to obtain industry and other stakeholder input in 2017. GSA received numerous responses from government agencies, industry, and other stakeholders.  Responses to the RFIs were used to help refine the Request for Proposals and the transition solution.

 

4. How does the SAM managed Identifier (SAMMI) support the Digital Accountability and Transparency Act (DATA) Act of 2014?

A data standard for identification of entities receiving Federal awards has been developed as part of the implementation for the Digital Accountability and Transparency Act. The Awardee/Recipient Unique Identifier is an existing federal spending data element in the Data Act Information Model Schema (DAIMS). The SAMMI will be utilized at the unique identifier and is an open, publicly available UEI that fully supports the data standards for identification of entities receiving Federal awards in accordance with the DATA Act.

 

5. When will the new SAM managed Identifier (SAMMI)  have to be used, and how will GSA share information on the SAMMI transition?

To enable a successful transition to the SAMMI while minimizing the impact to Government operation, IAE has planned for an extensive transition period implementing changes in IAE through a phased approach by 2020. Transition plans will be published at a later date, and IAE will be notifying all business partners, governance, and the Technical Interface Community (TIC) of the pending changes through our normal communication channels to ensure information is conveyed.

 

6. Will the entities still be required to create an account and register with a 3rd party entity validation service (EVS) provider to register in SAM.gov?

No, entities will no longer be required to create an account and register with a 3rd party EVS provider in order to register in SAM.gov. This acquisition incorporates a change in the entity validation process to begin and complete the process entirely in SAM.gov.   This single point of entry is a frequent request from entities using SAM and will greatly improve their user experience.

 

7. How will this impact FPDS reporting?

Beginning in FY20, submission of awards data to FPDS will utilize the SAMMI to identify the entity receiving the award.  For historical purposes, DUNS information will continue to be available for awards made prior to the SAMMI transition. GSA will be providing an implementation plan based on input from the user community to ensure a successful transition.

 

8. Will additional data elements in SAM.gov be available for public consumption?

The government intends to provide at least the same level of information currently available to the public in our systems. The government desires to provide publicly-available information in an open data environment.

 

9. Will we still be able to use the DUNS in federal agency systems?

Terms and Conditions in GSA’s contract with Dun & Bradstreet (D&B) were updated in 2016 to allow for D&B-sourced content to be used widely by the Federal Government (i.e., even for non-acquisition related purposes) and to remain in Government systems after the end of the D&B contract. This includes the use of data in compiling research of historical procurement information and conducting trend analysis. For historical purposes, DUNS information will continue to be available for awards made prior to the SAMMI transition.

 

10. In light of the recent alleged fraudulent activity in the System for Award Management (SAM), what is the General Services Administration (GSA) doing to prevent fraud in the future, and is this contract going to support that?

GSA has taken action to address alleged fraudulent activity in the System for Award Management (SAM). The measures GSA already put in place to help prevent improper activity in SAM include masking specific data elements in the entity registration even for authorized entity users; requiring “parent” approval of new registrations for their “child” entities; and requiring the formal appointment of the Entity Administrator by original, signed notarized letter.

Additional enhanced controls have been deployed. These controls include implementing multi-factor authentication using login.gov and notifying Entity Administrators when there is a change in the entity’s bank account information.

 

GSA  plans to regularly provide updates via the GSA Interact platform, and other public announcements, as appropriate.

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