FAR Compliance & Unique Entity Identifier Reminder

FAR Compliance and Unique Entity Identifier Reminder

June 26, 2023

Last year Lockheed Martin issued a series of communications making its subcontractors in receipt of purchase orders under USG prime contracts aware of the requirement for them, after April 2022, to obtain a Unique Entity Identifier (UEI) (even if not doing business direct with the USG) through the System for Award Management (SAM) at SAM.gov.

Any entities that were registered to do business with the USG prior to April of last year had DUNS numbers (i.e., a DUNS issued by Dun and Bradstreet) at SAM.gov and were automatically assigned new UEIs within SAM for each DUNS. Organizations with multiple DUNS registered in SAM obtained a UEI for each unique entity.

The only difference between DUNS numbers and UEIs is that entities are no longer required to rely on a third party (i.e., D&B) to obtain an identifier for doing business with the USG and/or being a sub-awardee to a USG subcontract. Accordingly - as with DUNS numbers - UEIs remain unique to specific names and physical addresses of entities. For questions relating to this aspect of UEI registration, visit https://sam.gov/content/duns-uei (please see the “Is the Unique Entity ID unique like the DUNS Number was?” question).

Pursuant to 2 CFR § 25.300, sub-awardees to USG subcontracts must obtain UEIs to be eligible to receive subawards. Please review your company’s formation structure to determine legal entity (ties) status and whether you need to obtain additional UEIs. If you have multiple DUNS numbers registered in our systems, you must provide a UEI for each location and profile in which the purchase order was placed. Please ensure that you provide us with UEIs associated with your entity’s registration may be updated in our systems.