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6. Capture only Universal Entity Identifier (UEI)

Introduced: 2022-04-11

Status

Decided

Context

The UEI is the new Universal Entity Identifier made available to the public through sam.gov.

We are moving the FAC during an identifier transition within the community. Specifically, the transition from the DUNS->UEI.

This raises a number of questions.

  1. Do we collect only the UEI?
  2. Do we collect both numbers?
  3. Do we try and link an old DUNS number to a new UEI number?
  4. Do we require the UEI before entering audit data?
  5. Do we require the UEI before recording audit data?
  6. Do we require the UEI before submitting audit data?

Decision

To the questions above:

  1. We will collect only the UEI.
  2. We will not collect or ask for a DUNS number.
  3. We will not try and link an old DUNS number to a new UEI.

To be clear, "collect" means "collect as a field on the SF-SAC." Separate conversation may still be needed in engineering regarding whether or not (say) an EIN should be retained from information retreived from sam.gov.

Consequences

The UEI is intended to be a single source of truth for entities applying for and receiving federal funding. Information like EIN numbers should be linked (and, in some cases, validated against authoritative sources) from and by sam.gov.

Historical connection to DUNS numbers is out of scope for the MVP. More research is required, but it is likely that this kind of linkage exists elsewhere in government.

The community has never submitted this identifer to the SF-SAC before. This will change the user's experience, but not their reporting burden, because they should already have a UEI. That said, we know that auditors are currently preparing the SF-SAC based on last year's form, and therefore they are not preparing grantees for this new number, or the UX changes the UEI represent.

So, there are consequences, but our steering committee (and internal discussion on the team) confirms that this is the correct path for the FAC MVP.

Notes

This was originally product decision record 0002; renamed/renumbered as part of merging ADRs and PDRs.