[Federal Register: June 27, 2003 (Volume 68, Number 124)]
[Notices]
[Page 38402-38405]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr27jn03-125]
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OFFICE OF MANAGEMENT AND BUDGET
Use of a Universal Identifier by Grant Applicants
AGENCY: Office of Management and Budget.
ACTION: Notice of final policy issuance.
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[[Page 38403]]
SUMMARY: The Office of Management and Budget (OMB) is issuing a policy
directive to implement the requirement for 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.
OMB has determined that there is a need for improved statistical
reporting of Federal grants and cooperative agreements. Use of the DUNS
number government-wide 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 DUNS number will be required whether an applicant is submitting
a paper application or using the government-wide electronic portal
(Grants.gov). By using the Grants.gov portal, entities will be able to
store in a central repository organizational information that does not
change from application to application. The DUNS number will be one of
those stored elements.
The DUNS number will supplement other identifiers required by
statute or regulation, such as tax identification numbers. It is our
intent over time to use the DUNS number throughout the grants life
cycle.
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. Organizations can
receive a DUNS number at no cost by calling the dedicated toll-free
DUNS Number request line at 1-866-705-5711. 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 are exempt from this requirement.
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; telephone 202-395-5642; or e-mail
sswab@omb.eop.gov.
SUPPLEMENTARY INFORMATION
A. Background
In a Federal Register notice [67 FR 66177] published on October 30,
2002, the Office of Management and Budget (OMB) proposed to establish
the DUNS number as the universal identifier for Federal grant and
cooperative agreement applicants. The OMB notice also included a
proposed policy to establish this policy as a government-wide
requirement. We received comments from 37 separate entities: 3
universities; 12 State/local governments; 7 non-profit organizations; 9
Federal agencies; 5 associations, and a for-profit business. We
considered all comments in developing the final policy. Comments
generally were in support of the concept of the Universal Identifier
although there were concerns about the use of the DUNS number and the
impact on certain types of recipients. These concerns are addressed in
the responses below. Other comments which were outside the scope of
this proposal, will be separately considered by the Grants.gov Program
Management Office or the Public Law 106-107 working groups, as
appropriate.
The following paragraphs summarize the major comments and our
responses. For simplicity, the term ``grant'' used in the following
section also means ``cooperative agreement''.
B. Comments and Responses
Comments on Applicability
Comment: Four commenters questioned whether the requirement to
obtain a DUNS number should be applied to individuals. They urged that
individuals that apply for grants directly from the Federal government
be exempted from the requirement to obtain a DUNS number in order to
apply.
Response: Agree. We clarified the policy directive to indicate that
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, are not required to provide a
DUNS number in order to apply for or conduct subsequent business with
the Federal government under a grant. Individuals may continue to apply
under programs for which they are eligible applicants without providing
a DUNS number.
Comment: Ten commenters indicated that applying the DUNS number
requirement to subrecipients would create difficulty and perhaps delay
primary applicants in preparing their funding requests.
Response: Agree. The final policy directive indicates that
applicants are not required to submit DUNS numbers for entities with
which they may enter into subawards. Only the primary applicant, i.e.,
the entity that makes application to the Federal government, including
State, local, and Tribal governments, and other entities receiving
block or other mandatory grants, will need a DUNS number at time of
application.
Comment: Five commenters recommended that non-U.S. recipients be
excluded from the DUNS number requirement since it would be difficult
for many foreign organizations to obtain the number.
Response: Disagree. Foreign applicant organizations which are able
to apply for a grant and meet the normal terms and conditions,
including reporting requirements should be able to apply for and
receive a DUNS number.
Comments on Numbering System/Alternate Process
Comment: Fourteen commenters recommended that the Federal Employer
Identification Number (EIN) be considered for the universal identifier
instead of the DUNS because it is already widely used during the
Federal government's administrative processing of grants, or that an
entirely new numbering system be designed.
Response: Disagree. Although other numbering systems currently are
in use (and will continue), none is adequate to identify family tree
relationships or can provide the access and validation capabilities
offered by the DUNS. Many potential applicants already possess DUNS
numbers. Further, the cost of developing and maintaining another
numbering system for grantees would not be justified.
Comment: One commenter recommended we use the Social Security
Number (SSN) as the universal identifier. The commenter suggested that
the DUNS number be used only for organizations, or other entities for
which a SSN would not be appropriate.
Response: Agree with the substance of the comment. We have exempted
individuals who would personally receive a grant or cooperative
agreement award from the Federal government apart from any business or
non-profit
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organization they may operate from the policy directive's
applicability.
Comment: Two commenters appeared to misinterpret our proposal for a
universal identifier and assumed that our intent was to have the DUNS
number replace all other identifiers. One commenter also suggested that
the multiple grant identifiers currently in use by various Federal
agencies should be replaced by DUNS, and the DUNS should be used
consistently throughout the grant life cycle to complement grant award
numbers.
Response: Agree. The final policy directive clearly states the
purpose of the DUNS and the continued existence of other numbering
systems. It also is our intent over time to use the DUNS number in
other parts of the grants life cycle, replacing other numbers if
possible.
Comments on Implementation
Comment: Six commenters expressed concern regarding the burden
required in obtaining a DUNS number for those organizations that do not
currently have one, with one noting a particular burden for small and
community and faith-based organizations.
Response: Disagree. OMB has determined that obtaining a DUNS number
is not a significant burden under the Paperwork Reduction Act. There
should be minimal burden on applicants. Obtaining a DUNS number is a
one-time activity. With use of the toll-free request line, there will
be an immediate DUNS number assignment at no charge to the requestor.
Comment: Nine commenters requested guidance for entities that have
multiple DUNS numbers. They were particularly concerned that large
organizations with multiple DUNS numbers may not use the appropriate
DUNS number when applying, which would result in inaccurate tracking.
They also questioned whether Federal agencies will be responsible for
verifying that applicants are using valid DUNS numbers.
Response: Agree in part. Dun and Bradstreet (D&B) will work with an
applicant to understand or change their numbers, however each
organization is responsible for controlling its own DUNS hierarchy. D&B
recommends a single point of contact for each entity. The DUNS will not
affect the ability of the entity to structure its organizational
delegations and authorities for submitting applications. A central
Federal repository [currently named the Business Partner Network (BPN),
formerly the Central Contractor Registry (CCR)], rather than individual
Federal agencies, will be responsible for performing periodic
verification of DUNS numbers.
Comment: Four commenters suggested that the universal identifier
might enhance the ability of State governments to track recipients of
Federal funds within their States. These commenters also requested
clarification of whether payment processes will be affected, for
example, if the DUNS number would be required as part of each request
to draw down Federal funds.
Response: No change. OMB is working to ensure that, for
applications subject to the DUNS number requirements, Federal grant
financial reporting, payment, and audit requirements are modified to
also incorporate use of the DUNS number. It is OMB's intent to expand
use of the DUNS number throughout the entire grants life-cycle.
Comments on Education/Outreach
Comment: Three commenters strongly recommended that applicants be
notified up front through both paper and electronic means of the need
to apply for a DUNS number before submitting a grant application and/or
verify their organization's DUNS number. In addition, they suggested
that applicants should know in advance what information they would be
asked to provide.
Response: Agree. Guidance on how to obtain a DUNS number, verify
whether an entity already has a DUNS number, and obtain copies of the
organization family-tree will be provided at the Grants.gov portal.
Links to this guidance will be included on Federal web sites, and it
will be used in outreach and other education efforts.
Comment: Three commenters asked for information concerning how the
Federal government will conduct outreach on the new policy within the
various grant communities. In particular, they asked whose
responsibility it is to inform the public. They suggested that OMB work
with technical assistance providers that currently provide services to
nonprofits on the outreach and educational efforts.
Response: Agree. Federal agencies will be responsible for notifying
their respective applicant/recipient communities of the change. A link
to the guidance on how to obtain a DUNS number will be available from
Federal web sites. In addition, we will work with associations
representing various constituencies for their assistance in ``getting
the word out.''
Dated: June 23, 2003.
Linda M. Springer,
Controller.
To the Heads of Executive Departments and Agencies
Subject: Requirement for a DUNS Number in Applications for Federal
Grants and Cooperative Agreements.
1. Purpose. This policy directive establishes the requirement that
applications for Federal grants or cooperative agreements include a Dun
and Bradstreet (D&B) Data Universal Numbering System (DUNS) number.
2. Authority. This policy directive is part of the implementation
of the Federal Financial Assistance Management Improvement Act of 1999
(Pub. L. 106-107). This policy is also designed to further implement
the E-Grants.gov initiative, one of the 24 electronic government (E-
Gov) initiatives under the President's Management Agenda.
3. Background. Public Law 106-107 requires the Office of Management
and Budget (OMB) to direct, coordinate, and assist Executive Branch
departments and agencies in establishing an interagency process to
streamline and simplify Federal financial assistance procedures for
non-Federal entities. It also requires executive agencies to allow
applicants to electronically apply for, and report on the use of, funds
from the Federal financial assistance programs administered by the
agency.
Under the E-Grants.gov initiative, the Federal 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.
4. Policy.
a. Applicability. This policy applies to all types of entities
applying for Federal grants or cooperative agreements under
discretionary and mandatory grant programs or activities except:
i. 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.
ii. Any applicant that receives an exemption, or an applicant under
a
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program that receives an exemption (see paragraph c. below).
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.
b. Effect. 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. Unless an exemption is granted, an application will not
be considered complete until a valid DUNS number is provided by the
applicant.
For Federal purposes, the applicant is not required at this time to
submit DUNS numbers for entities with which it may enter into
subawards.
The DUNS number does not replace existing 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 Order, or regulation.
c. Exemptions. Agencies may not grant exemptions from this policy.
Requests for exemptions must be directed to OMB.
5. Agency Responsibilities. Agencies that award grants or
cooperative agreements shall:
a. Issue any needed implementing direction to component offices to
meet the requirements of this policy directive.
b. Provide outreach and education appropriate to their applicant
communities regarding the requirement for a DUNS number. Agencies
should encourage entities that anticipate applying for Federal grants
or cooperative agreements to obtain a DUNS number in advance of a
specific application. Agencies should inform entities that it is their
responsibility to obtain a DUNS number.
c. Include this requirement in all funding opportunity
announcements issued on or after the effective date of this policy
directive with application due dates or acceptance dates on or after
October 1, 2003. For all other funding opportunity announcements with
due dates or acceptance dates on or after October 1, 2003, agencies
must amend their announcements or take other appropriate measures to
inform potential applicants of this requirement. These requirements
apply equally to other types of notifications if funding opportunity
announcements are not used.
d. Revise their grant and cooperative agreement applications and
plans to include a DUNS number. OMB approval is not required to add a
DUNS number field to previously approved forms.
e. Ensure that their grant-related processing systems, and other
systems as appropriate, are able to accept the DUNS number.
6. Information Contact. Direct any requests for exemption or
questions about this policy directive to Sandra Swab, Office of Federal
Financial Management, 202-395-5642 (direct) or 202-395-3993 (main
office), or via e-mail (sswab@omb.eop.gov)
7. Effective Date. This policy directive is effective 30 days after
issuance.
Dated: June 23, 2003.
Linda M. Springer,
Controller.
[FR Doc. 03-16356 Filed 6-26-03; 8:45 am]
BILLING CODE 3110-01-P