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As of April 4, 2022, the federal government will stop using the Dun & Bradstreet (D&B) Data Universal Number Systems (DUNS) Number to uniquely identify entities and will fully transition to using the Unique Entity Identifier (UEI). All entities will be using the UEI number for SAM and other government systems (including FPDS.gov, eSRS.gov, FSRS.gov, FAPIIS.gov, and CPARS.gov).  DUNS Numbers will no longer be searchable or viewable in SAM.  Those already registered in SAM should not need to take any action.

Purpose

The change is intended to allow for competition in the unique entity validation process by reducing the burden that would be associated with changing the vendors confirming that an entity is unique.  Now SAM will generate the UEI number so it is vendor independent.  The government will be able to compete and award contracts to do the unique entity validation process rather than be obligated to use D&B or any other particular vendor.

Timeline

The deadline to request a new DUNS Number or update existing entity information at D&B is March 29, 2022 at 5 p.m. EST.  SAM.gov will be down beginning April 1 at 8:00 p.m. EST until no later than April 4 at 9:00 a.m. EST.  During the transition, other government systems will experience intermittent downtime between March 31 and April 3.

Actions

No specific action is required for any entities already in SAM (active or inactive) and moving forward companies will no longer be required to update their DUNS registration (for instance in the event of a name change or address change) before updating SAM.  Those registering in SAM after April 4, 2022 or seeking a UEI after April 4, 2022 will request a UEI through SAM.gov.

Businesses can view their SAM UEI for each entity registered in SAM by logging into SAM and navigating to the entity’s registration page.  The SAM UEI is in the upper left corner under the DUNS currently, but the DUNS reference should be removed as of April 4, 2022.

SAM.gov has provided FAQs, videos, and an interactive graphic to help stakeholders understand the impacts of the UEI transition, new processes, and required actions.

   

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

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Photo of Stephanie Crawford Stephanie Crawford

Stephanie Crawford is a trusted counselor to a broad range of industries facing reorganizations, transactions, national security issues, and questions of supply chain management. Stephanie provides related mergers and acquisitions, counseling, litigation, international arbitration, and investigations services to clients in the aerospace and

Stephanie Crawford is a trusted counselor to a broad range of industries facing reorganizations, transactions, national security issues, and questions of supply chain management. Stephanie provides related mergers and acquisitions, counseling, litigation, international arbitration, and investigations services to clients in the aerospace and defense, communications, energy, information technology, and consumer products sectors.

Stephanie has substantial experience with both buy-side and sell-side transactions. She has led government contracts diligence for numerous private equity entities and defense contractors. She assists clients with navigating post-closing government requirements, including unique license transfers and approvals; novation and change of name regulations; and Defense Counterintelligence and Security Agency communications and foreign ownership, control, and influence (FOCI) mitigation.

Stephanie counsels clients on supply chain, sourcing, and national security regulations and requirements. Such counseling includes compliance with the Defense Production Act, including priority orders, ratings and associated regulations; the Public Readiness and Emergency Preparedness Act; and National Industrial Security Program Operating Manual (NISPOM) regulations. She is also known for her ability to solve immediate and business-threatening System for Award Management (SAM) and Defense Logistics Agency (DLA) CAGE Code problems.

Stephanie defends government contractors facing potential tort litigation with a nexus to their government contracts and facing supply chain and national security-related investigations, litigation, and arbitrations.

Stephanie’s pro bono practice focuses on a broad range of veterans’ issues, including disability ratings and discharge upgrades

Photo of Adelicia R. Cliffe Adelicia R. Cliffe

Adelicia Cliffe is a partner in the Washington, D.C. office, a member of the Steering Committee for the firm’s Government Contracts Group, and a member of the International Trade Group. Addie is also co-chair of the firm’s National Security practice. Addie has been…

Adelicia Cliffe is a partner in the Washington, D.C. office, a member of the Steering Committee for the firm’s Government Contracts Group, and a member of the International Trade Group. Addie is also co-chair of the firm’s National Security practice. Addie has been named as a nationally recognized practitioner in the government contracts field by Chambers USA.

Photo of Peter J. Eyre Peter J. Eyre

Peter J. Eyre is a partner and co-chair of Crowell & Moring’s Government Contracts Group. He is also a member of the firm’s Management Board. Peter was named to BTI Consulting Group’s list of “Client Service All-Stars” in 2016, 2017, and 2019 and…

Peter J. Eyre is a partner and co-chair of Crowell & Moring’s Government Contracts Group. He is also a member of the firm’s Management Board. Peter was named to BTI Consulting Group’s list of “Client Service All-Stars” in 2016, 2017, and 2019 and has been named an Acritas Star, Acritas Stars Independently Rated Lawyers (2016, 2017, 2019). He is nationally ranked by Chambers USA in Government Contracts since 2014, and by Super Lawyers since 2017.