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Panoptic Enterprises' FEDERAL CONTRACTS DISPATCH

DATE: June 27, 2003

SUBJECT: Office of Management and Budget; Use of a Universal Identifier by Grant Applicants

SOURCE: Federal Register, June 27, 2003, Vol. 68, No. 124, page 38402

AGENCIES: Office of Management and Budget (OMB)

ACTION: Policy Directive

SYNOPSIS: OMB is issuing a policy directive that will require grant applicants to provide a Dun and Bradstreet (D&B) Data Universal Numbering System (DUNS) number when applying for federal grants or cooperative agreements on or after October 1, 2003. This policy directive is part of the implementation of the Federal Financial Assistance Management Improvement Act of 1999 (Public Law 106-107), and further implements the Grants.gov (http://www.grants.gov) initiative, one of the 24 electronic government (E-Gov) initiatives currently being undertaken.

EDITOR'S NOTE: A DUNS number may be obtained at no cost from Dun and Bradstreet online at http://www.dnb.com/us/ or by calling the dedicated toll-free DUNS Number request line at 1-866-705-5711.

For more on other efforts to implement the Federal Financial Assistance Management Improvement Act, see today's FEDERAL CONTRACTS DISPATCH "Office of Management and Budget Circular No. A-133, Audits of States, Local Governments, and Non-Profit Organizations," and the June 23, 2003, FEDERAL CONTRACTS DISPATCH Office of Management and Budget; Announcements of Grants and Cooperative Agreements.

DATES: A DUNS number must be included in every application for a new award or renewal of an award, including applications or plans under mandatory grant programs, submitted on or after October 1, 2003.

FOR FURTHER INFORMATION CONTACT: Sandra R. Swab, Office of Federal Financial Management, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503; 202-395-5642; or e-mail: sswab@omb.eop.gov.

SUPPLEMENTAL INFORMATION: OMB has determined that there is a need for improved statistical reporting of federal grants and cooperative agreements. OMB believes the use of the DUNS number governmentwide will provide a means to identify entities receiving those awards and their business relationships. The identifier will be used for tracking purposes, and to validate address and point of contact information. The DUNS number already is in use by the federal government generally to identify entities receiving federal contracts and by some agencies in their grant and cooperative agreement processes. Among existing numbering systems, the DUNS is the only one that provides the Federal government the ability to determine hierarchical and family-tree data for related organizations.

The policy directive requires that "every application for a new award or renewal of an award, including applications or plans under mandatory grant programs, submitted on or after October 1, 2003, must include a DUNS number for the applicant." This requirement does not apply to "individuals who would personally receive a grant or cooperative agreement award from the federal government apart from any business or non-profit organization they may operate." Any other exemptions must be approved by OMB, not the granting agency.

The policy directive goes on to state, "For purposes of this policy, the applicant is the entity that meets the agency's or program's eligibility criteria and has the legal authority to apply. For example, a consortium formed to apply for a grant or cooperative agreement must obtain a DUNS number for that consortium. If a consortium is eligible, and the agency's policy is to make the award to a lead entity for the consortium, the DUNS number of the lead entity will be used."

The DUNS number will be required whether an applicant is submitting a paper application or using the governmentwide electronic portal http://www.grants.gov. Under the Grants.gov initiative, agencies are in the process of developing an electronic grant application system using standard core data elements. The DUNS number is one of those data elements. It will be used to link to fixed applicant data, such as name and address fields, maintained in a central federal registration repository. This will allow the data to automatically populate corresponding fields in the electronic application. Applicants will not have to re-enter this information on each electronic application they submit. The DUNS number requirement is also applicable to paper applications because of planned reporting requirements.

The DUNS number will supplement, not replace, existing identification numbers, such as the Employer Identification Number (EIN), the Tax Identification Number (TIN), and State Application Identifier (SAI) numbers that are required by statute, executive orders, or regulations.

In the introduction to the policy directive, OMB provides the following advice: "Organizations should verify that they have a DUNS number or take the steps needed to obtain one as soon as possible if there is a possibility that they will be applying for federal grants or cooperative agreements on or after October 1, 2003."

FOR FURTHER INFORMATION CONTACT: Panoptic Enterprises at 703-451-5953 or by e-mail to Panoptic@FedGovContracts.com.

Copyright 2003 by Panoptic Enterprises. All Rights Reserved.

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