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Reporting Requirements for Annual Financial Reports of State Agencies and Universities

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Reporting Requirements for Annual Financial Reports of State Agencies and Universities

Pass-Through Activity

Unique Entity Identifier – DUNS and SAM Reporting

State agencies and institutions of higher education that receive direct federal awards or pass-through from recipients of direct federal awards must have a unique entity identifier. According to the Code of Federal Regulations (2 CFR 25, Appendix A [C.2]), a unique entity identifier is the federal System for Award Management (SAM) registration number.

Data Universal Numbering System (DUNS)

According to the Office of Management and Budget (OMB) memo M-09-19, section 5, the DUNS number fulfills the unique entity identifier requirement for doing business with the federal government. A DUNS number is a unique nine-digit number provided by Dun & Bradstreet (D&B) that supplements other identification numbers. The OMB currently requires a DUNS number when applying for federal grants and cooperative agreements (see the Federal Register 68 FR 38402: “Requirement for a DUNS Number in Applications for Federal Grants and Cooperative Agreements”).

Until the OMB replaces DUNS numbers with another unique entity identifier format, any agency that receives direct or pass-through federal awards must maintain one or more active DUNS numbers. One purpose of the DUNS identifier is to validate address and point of contact information. Therefore, each agency must have a different nine-digit DUNS number for each physical location, address or legal division where the agency accepts federal awards.

Agencies may apply for a DUNS number from the D&B federal government website. D&B no longer accepts telephone applications. D&B customer support is available by calling (866)-705-5711 or emailing SAMHelp@dnb.com.

System for Award Management (SAM) Registration

The OMB established the SAM as the repository for standard information about federal award applicants and recipients (2 CFR 25.100 [b]). Unless otherwise exempt (by the program announcement, regulation or other issuance), an agency must register its DUNS in the SAM before applying for a federal award and maintain active SAM registration while the federal award is active (2 CFR 25.200 [b]).

DUNS Reporting in SEFA

Each agency must verify its reported DUNS number(s) every fiscal year during the SEFA final certification process. Agencies must include DUNS numbers for federal activity reported in that fiscal year’s SEFA. Agencies must remove DUNS numbers with no federal activity reported in that fiscal year’s SEFA.

Each agency acknowledges that it reported complete and accurate DUNS numbers during SEFA final certification when the agency checks the box next to the following statement:

“Our Agency has verified that its reported DUNS number(s) are complete and correct.”