If your DUNS Number had not been assigned by April 1, 2022, go to SAM.gov to register, or get a Unique Entity ID without using a DUNS Number. The UEI is assigned automatically to all active and inactive SAM.gov registered entities. This information is displayed on SAM.gov.
If you wish to register your entity, you can get a Unique Entity ID as part of your registration. You should also go to SAM.gov and get started. March 29 was the last day to obtain a new DUNS Number from Dun & Bradstreet for the purpose of getting a Unique Entity ID (SAM) or registering in SAM.gov. If you already have a DUNS Number, April 1 was the last day before the transition you can use it.
VIP!! DUNS Numbers will no longer be displayed or accepted for entity registration, reporting, or searching. The Unique Entity ID will be the identifier of record for anything Federal.
What does this mean for your SBIR/STTR proposal?
1. Your SAM account
It has always been critical to keep your SAM account valid and active during any work surrounding contracts or grants with the federal government. The system is, after all, not only a way for the funder to keep track of business entities and grant reporting but also the mechanism with which grantees are paid. However, now that all federal funding platforms have a new requirement for UEI numbers as business identifiers, it is now impossible to create and submit proposals without an active and valid SAM. SAM can expire quietly without the business owner knowing if close attention is not paid, wreaking havoc on the proposal preparation process.
Protip: Set a calendar reminder to renew it annually.
2. Maintaining Compliance
You might think, that’s not so hard, we can just renew our SAM. This is true, but the process is not likely to be simple or expedient. The SAM system handles hundreds of thousands of entities – every business that applies for any funding from the government (e.g., grants, contracts, etc), and all businesses that have been awarded previously are served by this system. The system operates on the standard business week and business hours (Monday through Friday, ~8 am to 4 pm). This is not a lean, agile high-tech business of the future either. This is a limited number of people working during a limited number of hours and beholden to bureaucratic protocols that are probably outdated. Getting SAM approval takes in a perfect world a minimum of three weeks. If any of multiple possible components is slightly off (e.g., misspelled words, selection of incorrect procurement codes, empty data fields to name a few honest mistakes) the registration process is delayed. We have seen clients struggle to get SAM approved for months.
Needless to say, grants and contracts have deadlines. Imagine completing your proposal only to find that SAM and in turn your UEI are not up to date and thus not recognized by the system thereby preventing timely submission. You could miss the submission window entirely which then creates a cascade of negative events such as having to wait until the next cohort window, resubmit your pitch, or potentially miss out on the opportunity altogether if it is a one-time contract or grant.
Here is an example of how ever-so-slight punctuation could delay the SAM approval Process. The BLUE one is correct.
- E.B. Howard Consulting
- EB Howard Consulting
- EBHoward Consulting
- E. B. Howard Consulting
Protip: However you have your company registered with the IRS should be the same in SAM. This includes spelling, capitalization, punctuation, etc.
3. How to proceed
Given the importance of an active and valid SAM (and how much time you likely spent getting it approved the first time you applied), it is worthwhile to maintain an active and valid SAM account once you obtain one. As a small business owner, there are countless other factors you keep track of every month (is the utility bill paid, is the liability insurance up to date, are we paying our business taxes correctly/on time?), simply add checking SAM to your master checklist of savvy business owner activities. This way, if it is set to expire in three months, you can start the process of re-registering early to avoid any gaps in compliance.
4. How this impacts sub-awards/collaborators
Remember back in the good old days before April 4th of this year when you could add any subaward organization you wished so long as they had a DUNS number? With the new implementation of UEI as an organizational identifier, you physically can not add another organization to your budget if they do not have an active and valid SAM account. While small businesses pursuing federal funding are likely to have a SAM account, businesses that have no need or interest in chasing federal grants and contracts are not likely to be registered with this system. Moving forward, every entity an applicant partners with for a subaward arrangement must obtain SAM registration prior to grant submission.
We recently tried to open a subaward budget in NSF’s Fastlane for a client only to find out that the subaward organization’s SAM registration had lapsed. The system did not recognize their UEI number since the SAM account was no longer active. We were unable to write the sub-awardee into the budget officially. As a result, the platform issued a warning for having subaward information in associated budget line items but not having a subaward organization on record within the proposal. Warning, unlike errors, do not prevent submission so the platform still allowed us to submit. However, submitting with a warning hanging over the proposal is deeply unsettling and not something we or our clients make a habit of.
What can applicants do to avoid this pitfall?
This means applicants will have to take extra care in selecting subawardees to ensure the company is willing to comply with the requirements of the grant. This sounds simple, but we have had many clients tell us about this “great” company they want to work with, only for said company to gripe and moan every step of the way about the nominal paperwork they have to provide to receive funds from the grant. Imagining past subawardees who gave us major pushback when we asked for something simple like a resume being tasked with registering for SAM is simultaneously comical and disconcerting.
As we always urge our clients to do, please perform due diligence on your potential subawardees. Make sure they are a legitimate, professional business capable of following all requirements. Make sure the point person does not have a deplorable attitude and is willing to work with you to get what is needed to submit the proposal. Remember, the sub-awardee is part of your team and your team is a reflection of your product/idea’s credibility and your credibility as a founder, but more on that to come in a subsequent post. That is a whole different tangent.