The General Services Administration (GSA) transition from the Dun & Bradstreet (D&B) Data Universal Number System (DUNS) to the Unique Entity Identifier (UEI), which took effect on April 4, 2022, has faced challenges. Substantial verification and validation delays continue, agencies have had to issue guidance for the management of SAM delays, and even Congress is showing concerns.
According to the Federal Service Desk (FSD), GSA requires entities to submit new validation documentation, despite the years of submissions to Dun & Bradstreet, because data rights limitations prevent SAM.gov from using previously validated data.
New entities and existing SAM-registered entities that cannot find a system-generated match to their legal name and associated physical address for a given SAM registration will be required to submit entity validation documentation. Similarly, entities changing their names or addresses will be required to submit entity validation documentation. GSA requires that the validation documentation (1) be of a certain type and include both the legal business name and current physical address on the same document, which must be less than five years old, and (2) be of a certain type and provide the state and date of incorporation or organization. A detailed list of acceptable documentation, unacceptable documentation, and the entity validation process can be found here. Companies have a limited time to submit sufficient documentation before SAM will close the validation submission/help ticket.
This entity validation process presents challenges particularly for entities that have undergone name changes, address changes, mergers, or other transactions; corporate entities with multiple SAM-registered physical locations; foreign entities submitting documentation with which SAM is unfamiliar; entities whose corporate address documentation is more than five years old; and entities primarily using unregistered “doing business as” names or other operating names.
Key Takeaways
- Begin updating your SAM registration early enough to address potential processing delays.
- Collect entity validation documentation before submitting a validation request.
- When submitting a validation ticket, provide a clear description of the validation documentation submitted and what the documents show (legal name, address, state and date of incorporation).
- Keep records of ticket numbers, dates of submission, information submitted, and chats or telephone calls with GSA/SAM/FSD.
For further information, please contact:
Stephanie L. Crawford, Partner, Crowell & Moring
scrawford@crowell.com
