As discussed in a March 2021 Streamline Verify article, SAM.gov went through an extensive overhaul to improve functionality and accessibility. First introduced as a beta site and then revised based on user feedback, the new site replaced the existing one in 2021. The new SAM.gov site has not generated many substantive comments from users, positive or negative. However, the recent decision to transition from using the Dun & Bradstreet identifier to a GSA-generated unique identifier on that site has not been as smooth.

Users were notified of this change on the SAM.gov website:

On April 4, 2022, the unique entity identifier used across the federal government changed from the DUNS Number to the Unique Entity ID (generated by SAM.gov).

• The Unique Entity ID is a 12-character alphanumeric ID assigned to an entity by SAM.gov.
• As part of this transition, the DUNS Number has been removed from SAM.gov.
• Entity registration, searching, and data entry in SAM.gov now require use of the new Unique Entity ID.
• Existing registered entities can find their Unique Entity ID by following the steps here.
• New entities can get their Unique Entity ID at SAM.gov and, if required, complete an entity registration.

The intent of this change was to streamline the entity identification process and make it easier to contract with the federal government, as well as to eliminate the use of a vendor such as Dun & Bradstreet to manage government contractors.

This new approach represents a major departure for the federal government, which has used Dun & Bradstreet for both vendor identification and validation services since 1978. Over the years, the required use of a DUNS number identifier issued by Dun & Bradstreet continued to expand to federal contracting and assistance across multiple agencies, until this very recent change by the General Services Administration (GSA). 

The UEI is a 12-character unique number assigned to an entity (public or private company, individual, institution, or organization) that must register in SAM.gov to do business with the federal government. For entities currently in SAM, no action was required to obtain a UEI. However, registered contractors still need to modify their internal systems to eliminate use of the DUNS# and introduce the new UEI for federal contracting purposes.

However, on May 3, 2022, the GSA issued the following notice on its blog which gave insights on the progress of the transition:

Last month, the new Unique Entity ID generated in SAM.gov became the official, governmentwide identifier used for federal awards. To continue to help users during the transition, there will be an automatic, 30-day extension for any existing SAM.gov entity registrations needing to be renewed with an expiration date ranging between Friday, April 29, 2022, and April 28, 2023. No action is required on the part of entity registrants.

Each impacted registration renewal will have 30 days added to their expiration date. As an example, an entity registration set to expire on June 1, 2022 will automatically be granted a 30-day extension to July 1, 2022. Entity administrators impacted by this change will receive an email from [email protected] with the subject line “30-Day SAM.gov Extension Granted for [Entity Name/Unique Entity ID/CAGE].”

The new expiration dates will be included in the SAM entity management extracts and available through web services after the records are extended. We will process the extensions in a deliberate, incremental manner over the course of several weeks. This will allow the U.S. government systems which rely on our data to consume it on their normal cadence.

Over the summer, complaints to elected officials began to surface. Rep. Gerry Connolly (D-Va.), chairman of the Oversight and Reform Subcommittee on Government Operations, wrote to GSA on July 15 about the transition to the Unique Entity Identifier from the DUNS number.

“According to many of my constituents, they have encountered significant difficulty in migrating their existing contractor accounts into the new framework, jeopardizing their businesses and their ability to pay their workers. I write to request information on GSA’s transition to a new Unique Entity ID (UEI) and to determine whether GSA is providing all necessary assistance to the federal business partners federal agencies rely on every day. I have heard from constituents who have struggled to transition to the new unique identifier — and in some cases were removed entirely from the GSA online system. Moreover, when seeking help and assistance from GSA, these government partners were often provided links to unhelpful online frequently asked question pages or stuck on telephone calls for hours with customer service representatives who were unable to help troubleshoot the problems.”

Throughout the summer of 2022, the GSA issued instructions about obtaining a new UEI on its website and blog. The GSA has produced a presentation that explains the new GSA process for identity validation that had previously been done by Dun & Bradstreet. On September 14, 2022, an online stakeholder meeting was held by the GSA to answer as many questions as they could.

A recent notification from the Department of Defense is another indicator that the transition away from using Dun & Bradstreet for identification and validation of federal contractors has not been a smooth process. As reported on the Federal News Network site on September 13, 2022, “The delays have gotten so bad with the transition to the new unique entity identifier (UEI) on SAM.gov that the Defense Department isn’t requiring contractors to have a new number to do business with them for the next six weeks.”

The Defense Pricing and Contracting office issued a deviation to the Federal Acquisition Regulation (FAR) on Sept. 8 that allows the services and defense agencies to do business with companies who aren’t fully registered in the governmentwide acquisition system. The issuance included the following statement:

Effective immediately, contracting officers may apply the procedures of FAR 4.1103(b) for offeror registration in the System for Award Management (SAM) as if the procurement were issued using the SAM exemption located at FAR 4.1102(a)(5), when an offeror can prove it has initiated or attempted to start the SAM registration process. These procedures allow the offeror to not be actively registered in SAM until 30 days after award or the date of its first invoice, whichever comes first. This deviation is issued to mitigate delays in SAM registration currently being experienced by entities due to changes in entity validation processes and a significant increase in entities requesting a unique entity identifier at SAM.

Conclusion

Unlike the methodical process used to develop, test and deploy the new SAM.gov site, the transition to a new GSA identification and validation process has been plagued with industry frustration and confusion. Companies have reportedly experienced difficulties and delays in both obtaining a UEI, as well as long wait times at the GSA call center. As demonstrated by the DoD issuance, the effect of this problem is being felt by government agencies more than five months after the transition to UEIs was mandated by the GSA. It remains unclear what steps the GSA can take to remedy this situation, aside from increased outreach and improved response times for contractors and users of SAM.gov.