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Just Announced: Your Questions Answered About the New Unique Entity Identifier (UEI)

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Centre Law & Consulting

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BREAKING NEWS FROM GSA

In late July, GSA hosted a live event about upcoming changes to the new Unique Entity Identifier (UEI) requirements (used to identify companies and individuals within the federal award process).  More than 770 people participated in the event.

The presentation provided detailed information about how IAE is moving away from using the D-U-N-S® number to a new, non-proprietary identifier. 

During the program, we received numerous questions from participants.  As promised, GSA has provided answers to those questions online at in the UEI information center on GSA.gov.

While all of the questions-and-answers can be found there, here’s a sample of some of what was asked and answered: 

Will GSA automatically assign the new UEI, or does the entity have to take action to register? Existing registrants will be automatically assigned a new UEI. New registrants will be assigned a UEI as part of their SAM registration.

As an existing entity, will we be notified of our automatically-assigned UEI?  A notification process will be established so that entities can find their assigned UEI

Do you have to be active in SAM.gov to get a UEI assigned? No, UEIs will be assigned to active and inactive entity registrations.

Will the UEI be available for registering entities immediately or will they have to wait a period (like with obtaining a DUNS today) for the UEI to become active before it can be registered?  UEI assignment times will be dependent on how quickly entity uniqueness and validation can be accomplished. It is the goal to make the UEI response time immediate for a large percentage of UEI assignment requests.

Will the format (character length, alphanumeric, etc.) of UEI be the same as the existing DUNS? No. The format will not be the same. Please see the following Federal Register notice for the new unique entity identifier standard: https://www.federalregister.gov/documents/2019/07/10/2019-14665/unique-entity-id-standard-for-awards-management

When including alphabetic characters in the UEI, will those alphabetic characters be stored / displayed as capital letters or lower-case letters? For example, A, B, C or a, b, c?  Capital letters will be used in the UEI.

What kind of reference data elements / underlying data will be captured for each of the UEIs?  When requesting a Unique Entity Identifier, the entity will provide basic data (e.g. legal entity name, doing business as name, physical address) which will be used to validate uniqueness. During the full SAM entity registration process, the entity will provide the same comprehensive data set they do today.

Will there be a hierarchy of UEI like there is for DUNS that relates “child” entities to their “parent” entities?  Yes, a hierarchy of entities will continue to exist within SAM. 

Will the actual cutover date be in December 2020?  There is going to be a lengthy transition period during which IAE will provide specific transition activities and cutover dates. By December 2020, the SAM generated UEI will be the authoritative unique entity identifier in SAM. 

Why can’t we use the EIN as the Unique Entity Identifier?  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. 

if you have questions or need guidance, please reach out to Maureen Jamieson at mjamieson@centrelawgroup.com.


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