(GENERAL-22-52) REMINDER #2 – Institutions Must Complete the Transition to the Unique Entity Identifier (UEI)

Author
Federal Student Aid
Electronic Announcement ID
GENERAL-22-52
Subject
REMINDER #2 – Institutions Must Complete the Transition to the Unique Entity Identifier (UEI)

On April 4, 2022, the General Services Administration (GSA) began using the Unique Entity Identifier (UEI) as the authoritative identifier for all entities doing business with the federal government and discontinued using the Data Universal Numbering System (DUNS) Number. The DUNS Number is no longer valid for federal award identification. As of that date, the U.S. Department of Education (Department) has also adopted the UEI for all of its systems.

Each institution that had an “active” registration status in the GSA’s System for Award Management (SAM) website (SAM.gov) automatically received a UEI that was shared across the Department’s systems, as described in a February 28, 2022 Electronic Announcement. Other institutions have subsequently registered and the assigned UEI has been shared. However, some institutions still do not have a UEI and/or an “active” registration status and are therefore unable to access critical Department systems. These institutions must complete the entity registration process in SAM.gov as soon as possible in order to obtain an active registration status and a UEI if needed, and to regain access to the Department’s systems for drawing down and reporting disbursements of Title IV, HEA funds.

This announcement describes the process for registering, obtaining a UEI, and reporting the UEI to the Department, and provides helpful tips for schools experiencing challenges with this process; explains the consequences of failing to complete the UEI transition and when a school might need multiple UEIs; reminds schools about the annual renewal process for entity registration; and reminds the community that obtaining a UEI is free and does not require the services of an outside party.

Entity Registration and UEI Assignment Process

Institutions that have not yet completed the transition from a DUNS number to a UEI in the Department’s system should take the following steps.

First, determine if your institution has been assigned a UEI. If your institution is currently registered in SAM.gov with either an active or inactive registration, or has signed up to receive a UEI, you have already been assigned a UEI. Your UEI is viewable on your entity’s workspace in SAM.gov. To learn how to view your UEI, see: How Can I View my Unique Entity ID? If your institution has not been assigned a UEI, you will need to register your entity. You can access instructions addressing how to complete your entity registration at: Get Started. If your institution has been assigned a UEI, you will need to check the status of your registration:

  • If your SAM.gov registration status is showing as “Active Registration,” you will need to verify that the address on file with SAM.gov matches the address provided to the Department on the Application for Approval to Participate in Federal Student Financial Aid Programs (E-App), and/or that the Employer Identification number (EIN) on file with SAM.gov matches the Taxpayer Identification Number (TIN) reported on the E-App.

  • If your SAM.gov registration status is showing as “Inactive Registration,” you have been assigned a UEI, but you will need to renew your registration. You can access instructions addressing how to renew your entity registration at: How to Renew or Update an Entity.

  • If your SAM.gov registration status is showing as “ID Assigned,” you have been assigned a UEI, but you will need to complete the entity registration process. You can access instructions addressing how to complete your entity registration at: Get Started.

If you need to register or renew your entity registration, you will be required to complete the entity validation process. To complete this process, you must attach acceptable documents that prove your institution’s legal business name, physical address, date of incorporation, state of incorporation (for domestic institutions) or national identifier (for foreign institutions). More information about the appropriate documentation to attach can be found here.

Please review the information at the above link carefully, as the GSA has found that most challenges in completing the UEI transition process occur during the validation phase. For example, some institutions found they could not complete validation because they did not provide a correct year of incorporation, provided an outdated address, or failed to include “LLC” at the end of their legal business names. In addition, you will need to make sure that the address on file with SAM.gov matches the address provided to the Department on the E-App, and/or that the EIN on file with SAM.gov matches the TIN reported on the E-App.

Upon verification that your institution has an active registration with an address and/or EIN in SAM.gov that matches the information reported on the E-App, you will need to report the institution’s UEI to FSA by email to the School Participation Division responsible for your institution. You can find the email addresses for the School Participation Divisions on the E-App web site here. Include with your notification screen shots from SAM.gov showing the registration status, address, and EIN.

The GSA provides additional information on the process for transitioning from a DUNS number to a UEI here. The Federal Service Desk also provides a series of helpful questions and answers about the entity validation process.

Annual Renewal of Registration

Note that while the UEI number will never expire, entity registrations do. Institutions must renew their registration annually in SAM.gov and can find their registration expiration date on the entity record in SAM.gov. The UEI transition process does not change your institution’s normal registration renewal cycle. Therefore, you may receive a notification that your registration renewal will begin soon after the UEI transition.

Consequences of Failing to Complete the UEI Transition Process

When the School Participation Division receives notification from the institution of the active registration status and assigned UEI, that information is shared with the Department’s systems used in processing Title IV funding. Failing to maintain an active registration will cause an institution to lose access to critical Department systems for drawing down and reporting disbursements of Title IV aid and other Department of Education or federal grants.

Grants Management System (G5)

Any school that does not have a UEI in G5 cannot draw funds from or return funds to the Department through G5 until that school completes the registration process, receives a UEI, and reports the UEI to the Department.

Common Origination and Disbursement (COD) System

The Common Origination and Disbursement (COD) System will accept Pell Grant, Iraq and Afghanistan Service Grant, TEACH Grant, and Direct Loan records. However, if a school does not have a UEI in the COD System, the COD System will reject the record (for all award types) with Reject Edit 996; the edit will be returned on the <RoutingID> tag. For more information about COD System changes for the UEI, refer to the Department’s March 18, 2022 Electronic Announcement.

Institutions may have separate UEIs for different federal programs and should ensure that they have completed the transition process for all their UEIs, including those associated with Department systems for drawing down and reporting disbursements of Title IV aid.

Institutions may also need separate UEIs for approved additional locations if Direct Loan Program funds will be disbursed using the location identifiers. If a UEI is needed for an additional location, the institution must follow the same process as above for Entity Registration and UEI Assignment.

No Cost to Obtain a UEI

SAM.gov is the official free, government-operated website for the management of government awards. There is NO charge to register or maintain your entity information in SAM.gov.

The Department has become aware that private companies have charged institutions to assist with the completion the registration process for institutions, and some charge an annual fee to ensure that an institution’s UEI is correctly maintained. The Department is not affiliated with and does not endorse such companies.

Contact Information

If you have questions about the SAM website or the registration process, contact the Federal Service Desk at 1-866-606-8220.

For questions related to G5, contact the G5 Hotline at 1-888-336-8930 or by email at edcaps.user@ed.gov. For questions related to the COD System, contact the COD School Relations Center at 1-800-848-0978 or by email at CODSupport@ed.gov.