How REI supported GSA in transitioning from DUNS to UEI

by Pradeep Krishnanath and Gissa Sateri 

REI Systems was proud to support GSA overcome technological and logistical challenges to help the Federal Government make the transition from using the proprietary DUNS number to a new, non-proprietary Unique Entity Identifier (UEI). The transition is just one part of GSA’s cloud-based application modernization of its Integrated Award Environment (IAE) – and yet is perhaps the most publicly visible part of that modernization. Now that the transition has been successfully completed, this blog describes why and how the transition was undertaken to provide an example that may be useful to other agencies and their supporting vendors.

Background, and Why GSA Sought This Change

To manage transactions with vendors, grantees, and some benefit recipients, the Federal Government must be able to identify with certainty the vendor, grantee, recipient, or other entity. As the lead agency for managing acquisitions, GSA has coordinated this effort to ensure certainty around entities that will receive payments from the government. This certainty ensures that each payment is properly made to the correct entity. Historically, GSA has used Dun & Bradstreet’s (D&B’s) Data Universal Numbering System (DUNS) to ensure identification of entities, but the proprietary DUNS tied GSA to D&B on terms that GSA eventually found disadvantageous. For that reason, GSA chose to introduce non-proprietary Unique Entity Identifier (UEI) to serve the purposes for which it had previously used DUNS.

D&B provided, pursuant to its contract with GSA, seven types of software products and fourteen data products that enabled the government to use DUNS for a variety of acquisition-related functions, such as paying contractors. These products supported approximately eighty data systems within the Federal Government.

While DUNS and associated business information are owned and controlled by D&B, they were licensed to the government to be used for selected acquisition purposes. The cost of using DUNS over the past two decades was in the hundreds of millions of dollars (see: analysis by the Federal News Network). From 2015 through 2020, GSA spent more than $26 million per year, on average for its contract with D&B, compared to about $1 million in 2002, the latter confirmed by a GAO review. In addition to rising costs, restrictions on the government’s data rights and a lack of competition to provide an entity identifier raised concerns about the government’s use of DUNS as a unique identifier. The UEI system addresses those concerns by providing unlimited data rights, greater transparency, and long-term cost savings as it is now government-owned and non-proprietary.

How GSA Launched the Effort

The transition from DUNS to the UEI system was a government-wide initiative. To ease the transition away from DUNS, GSA led the Government to ask that REI develop the UEI system, in part, because UEIs can be both requested in and generated by the GSA’s existing System for Award Management (SAM.gov). The transition of identifiers only needs to happen once, even if a different entity validation service provider is selected in the future. Entity validation services are not connected to the identifiers themselves.

The REI Implementation Team’s Role

REI Systems was competitively selected to join GSA’s IAE program in October 2015 as the lead vendor to modernize IAE applications on what is now known as GSA’s FAS Cloud Services platform (which leverages AWS cloud infrastructure). Collaborating with GSA, in a multi-vendor environment, REI leveraged microservices-based application development and agile software development practices that were at the cutting edge of technology innovation. REI spearheaded integration into the recently modernized beta.SAM.gov of multiple predecessor systems, including FBO.gov (Federal Business Opportunities – for contracting opportunities), CFDA.gov (Catalog of Federal Domestic Assistance listings), WDOL.gov (Wage Determination OnLine), and FPDS Reporting (Federal Procurement Data System Reporting – a databank). As part of the detailed transition plan, the System for Award Management (SAM) was developed and initially made public in beta format, but GSA has recently transitioned over to rely fully upon SAM.gov, and thus deleted the “beta” prefix. REI partnered with GSA, to modernize SAM.gov and prove the value of using the Scaled Agile Framework (SAFe) for delivery of large-scale government services.

In November 2020, REI won a 5-year Task Order under the GSA COMET BPA to complete the modernization and operation and maintenance of SAM.gov. One major initiative on that most recent contract was the migration from DUNS to the UEI system. That migration included moving both transaction functionality, as well as an enormous data migration effort.

How We Did It

REI’s key contributions to support the governmentwide transition to and implementation of the UEI system included:

• Developed a registration process and the ability to provide corporate linkage information and data verification and monitoring capabilities using a UEI number.
• Proposed a UEI structure and developed a UEI generation service.
• Identified federal and non-federal hierarchy and workflows.
• Developed an entity validation service for validating the entity. Also used that service to maintain the entity/vendor hierarchy.
• Migrated the data and updated the services to use UEI from DUNS.
• Designed a solution to be loosely coupled with entity validation provider.
• Developed a more convenient and efficient user-centric interface, eliminating the need for users to go to multiple sites and interact with a third party directly. Now, users can go to SAM.gov, provide the information or request a unique entity identifier, get the entity validation done.

With a solution that included the above elements, GSA can provide customer-centric services, use a government-owned entity identifier, and obtain full and open competition as it contracts for entity validation services.

Results of This Effort

The transition from DUNS to the UEI system has been extremely successful. The now integrated IAE systems (SAM.gov, FPDS, eSRS, FSRS, CPARS, and FAPIIS) are fully operational and have demonstrated stable performance using the UEI. Thousands of users successfully have requested their UEI by following the new entity validation process. Furthermore, users have successfully utilized the new business process to create service tickets directly through SAM.gov to request support for their entity validation.

Further, success of the DUNS-UEI transition has been evidenced, within a few short weeks, by:

• Over 46,000 new vendors have registered to do business with the government – this may be attributable in significant part to the increased ease of doing business made possible by the modernization of IAE, and effective planning and execution of the DUNS-UEI transition.
• Successful and secure data migration, exemplified by the seamless and secure transition of vendor data to the new Unique Entity Identifiers (UEI).
• Significantly lower expected operating costs based on the non-proprietary identification tool, and a savings of nearly $12M per year based on GSA’s new ability to use competition as it seeks entity validation services.

Despite the high risk of transitioning between publicly visible systems in operation, there has been no gap in service, no data breaches or security issues, and no significant customer complaints. In fact, in the two months after the transition, all indications are that it has been a complete success. This was one of the most (if not the most) complex, government-wide transitions of the last few decades, but the technical transition from the DUNS Number to the Unique Entity ID created no disruptions in vendor bid submissions, government evaluations of bids, payments to vendors or other recipients (i.e., grant recipients). All IAE systems are operational and demonstrating stable performance using the Unique Entity Identifier. And for the few technical and performance issues that arose during testing, the launch cycle, and these first months of operations, our team worked together to effectively identify, diagnose, and resolve each issue.

Finally, the transition from DUNS to UEI is just a small part of a much larger application modernization effort that GSA is undertaking, with REI as the lead vendor, to modernize the entire portfolio of Integrated Award Environment (IAE) systems that GSA uses to manage Federal Government’s relationships and transactions with vendors, grant recipients and other entities.  As part of the IAE application modernization effort, REI’s team has helped to decommission and replace the functionality of outdated legacy systems including FBO.gov, CFDA.gov, WDOL.gov, FPDS.gov Reports, and PPIRS.gov. At the same time, as part of the IAE program, we’ve helped GSA to integrate additional systems into the core of IAE, accessible via SAM.gov (the System for Award Management). Those additional systems include eSRS, FSRS, CPARS, and FAPIIS. This broad IAE application modernization effort will continue for several more years, with the successful DUNS-UEI transition representing just the most recent milestone.

We successfully executed an effective model for collaboration and look forward to GSA’s future success using technology to strengthen the government’s buying power, to get the best possible deal for America’s taxpayers.