DUNS and SAM Registration Requirements

5.1 What is the purpose of this chapter? This chapter provides the information employees working with grant and cooperative agreement awards need to:

A. Monitor recipients for compliance with the Data Universal Numbering System (DUNS) and System for Award Management (SAM) registration requirements, and

B. Implement the Department of the Interior’s Guidance Release 2012-08: DUNS and Central Contracting Registration (CCR) Requirements for Grants and Cooperative Agreements.

5.2 What are the objectives of this chapter? Our objectives are to:

A. Ensure employees working with grants and cooperative agreements are aware of the DUNS and SAM registration requirements and of their responsibilities to communicate the requirements to applicants and recipients,

B. Establish and implement a process for waiving the DUNS and SAM registration requirements for qualified entities, and

C. Implement centralized Servicewide monitoring to ensure grant and cooperative agreement award recipients maintain active SAM registrations.

5.3 What is the scope of this chapter? This chapter:

A. Covers all programs that administer and manage grant and cooperative agreement awards, but

B. Does not apply to any individual applying for or receiving Federal funds under a grant or cooperative agreement award separate from a business or non-profit organization the individual may operate. The Office of Management and Budget (OMB) exempts these individuals from the DUNS and SAM registration requirements.

5.4 What are the authorities for this chapter?

A. Pre-Award Responsibilities, Universal Identifier and Central Contractor Registration (2 CFR Part 25).

B. U.S. Department of the Interior Guidance Release 2012-08:DUNS and CCR Requirements for Grants and Cooperative Agreements.

5.5 Who is responsible for ensuring recipient compliance with the DUNS and SAM registration requirements? See Table 5-1.

Table 5-1: Responsibilities for Ensuring Recipient Compliance with the DUNS and SAM Registration Requirements

5.6 What is DUNS and its registration requirement?

A. DUNS is a system developed and regulated by Dun & Bradstreet (D&B) that assigns a unique nine-digit number, referred to as a "DUNS number," for each of an entity’s physical locations. The number is associated with key business information, such as name and address.

B. Regulations require entities that either apply for or receive Federal funds under grant and cooperative agreement awards, or receive subawards directly from entities that receive grant and cooperative agreement awards, to obtain a valid DUNS number, unless the entity is exempt (see section 5.3B) or the Service waives the requirement (see section 5.8).

C. Entities that have to register to get Federal contracts, grants, and cooperative agreement awards can get a DUNS number for free. Information about how to obtain a DUNS number is available on the company’s Web site.

5.7 What is SAM and its registration requirement?

A. SAM is a Federal procurement and financial assistance Web site that consolidates the functionality that was previously in such systems as the CCR, Federal Agency Registration (Fedreg), the Online Representations and Certifications Application (ORCA), and the Excluded Parties List System (EPLS).  

B. Regulations require entities that apply for or receive Federal funds under grant and cooperative agreement awards to register and maintain current information in SAM unless the entity is exempt (see section 5.3B) or the Service waives the requirement (see section 5.8).

C. To maintain an active registration in SAM, recipients must review and update their SAM information at least annually after the initial registration, and more frequently when information changes.

5.8 May the Service waive the DUNS and SAM registration requirements for an entity? 

A. Yes, but because we need to ensure transparency of Federal funding, we may only approve a waiver if one of the following criteria is met:

(1) We must protect information about the entity from disclosure to avoid compromising classified information or national security or jeopardizing the personal safety of the entity’s clients, or

(2) A foreign entity is applying for or receiving an award for less than $25,000, the project will be conducted outside of the United States, and we find it impractical for the entity to comply with the requirement (see section 5.10 for information about what has to happen if the award reaches $25,000 or more).

B. If one of the criteria above is met:

(1) We can waive the requirement for both the DUNS and SAM registration, or

(2) If the recipient has a DUNS number but cannot register in SAM, we can waive just the SAM registration requirement.

5.9 What is the process to request a waiver?

A. To request a waiver, the program must:

(1) Obtain from the entity a written justification supporting the criterion/criteria (see section 5.8A).

(2) Complete FWS Form 3-2451, Financial Assistance Recipient DUNS/SAM Registration Waiver. The managing Directorate member must sign and date the waiver request form. Someone “Acting” for the Directorate member may sign the form in his/her/their absence, but the signature cannot be delegated below the “Acting” level.   

(3) Route the written justification and completed waiver request form in the Data Tracking System (DTS) to the AD-WSFR.

B. The AD-WSFR will send the request to the Branch Chief, FAPO. FAPO staff will:

(1) Recommend to the AD-WSFR whether or not to approve the waiver request based on the criteria in section 5.8A, and

(2) Maintain a list of all approved and denied waivers.

C. The AD-WSFR or his/her/their Acting must approve or deny the waiver request by signing and dating the waiver form.

D. After the program receives the waiver decision from the AD-WSFR, program staff must:

(1) Maintain the form in the official award file, and

(2) Send the entity a copy of the form.

5.10. What happens if a foreign entity receives a waiver, but the total Federal award amount is later increased to $25,000 or more? Once the cumulative total Federal award amount becomes equal to or greater than $25,000, the waiver is automatically revoked, and the foreign entity must register in SAM. To ensure compliance with the funding limit, FAPO monitors all financial assistance awards to foreign recipients with waivers to ensure they do not reach or exceed the $25,000 limit. 

A. When such an award equals or exceeds the $25,000 limit, FAPO must:

(1) Notify the Grants Specialist or other managing officer that the recipient’s waiver is revoked and that the recipient needs to register in SAM to continue receiving payments,

(2) In coordination with any other impacted Departmental bureau(s), request that the Financial and Business Management System (FBMS) Vendor Master Data Maintenance team place a payment block on the recipient’s vendor record in FBMS, and

(3) After the recipient registers in SAM, work with the FBMS Vendor Master Data Maintenance team to make necessary updates to the recipient’s FBMS vendor record and remove the payment blocks.

B. The program that initiated the waiver request must:

(1) Communicate with the recipient until their SAM registration is complete, and

(2) After the recipient registers in SAM, notify FAPO that the registration is complete and provide the recipient’s DUNS number if the recipient was not previously registered in DUNS.

5.11 What must Service programs do to ensure applicant and recipient compliance with the DUNS and SAM registration requirements? We must:

A. Include the DUNS and SAM registration requirements in the full Notice of Funding Availability and Application Instructions document that is attached to the Grants.gov synopsis when we post a funding opportunity on Grants.gov,

B. Include reference to the 2 CFR Part 25, Appendix A award term in every grant and cooperative agreement award notice,

C. Unless the entity is exempt or receives a waiver (see sections 5.3B and 5.8), and before obligating funds for a new award:

(1) Confirm that the entity has an active registration in SAM. Search for the entity in SAM (typically by searching by the DUNS number the entity puts on their application),  

(2) Make sure that the DUNS number associated with the entity’s active SAM registration matches the DUNS number on the FBMS vendor record for the award, and

(3) Include the following statement in every notice of award:

Under the terms and conditions of this award, your organization must maintain an active SAM registration until the final financial report is submitted or final payment is received, whichever is later. If your organization’s SAM registration expires during the required period, the U.S. Fish & Wildlife Service will suspend payment under this and all other Service awards to your organization until you update your organization’s SAM registration. 

D. Before releasing an award revision, confirm that the recipient’s SAM registration is still active. We must not provide additional funding or extend an award period of performance to a recipient with an inactive SAM registration.   

E. Monitor SAM registration expiration dates and remind recipients with upcoming expiration dates of their responsibility to maintain an active SAM registration. We can use the FBMS Enterprise Management Information System (EMIS) reporting to monitor SAM registration expiration dates.

F. FAPO staff may test for compliance with the SAM registration requirements. If FAPO detects an expired SAM registration, they will notify the affected Grants Specialist(s) or other managing officer that the recipient is out of compliance.

5.12 What happens when a recipient’s SAM registration expires? FBMS automatically places blocks that prevent the obligation of new funds to the recipient and the release of payments requested through the Interior Business Center (IBC).

5.13 What must the Service do when a recipient’s SAM registration expires? We must:

A. Hold all payment requests that the IBC will process until the recipient updates their SAM registration.

B. For recipients receiving funds through the U.S. Treasury’s Automated Standard Application for Payment (ASAP) system, block all payments to the recipient by placing their awards on “Agency Review” status until the recipient updates the SAM registration.

C. As soon as practical, but no later than 30 calendar days from the date that the inactive SAM registration was identified, issue a letter, fax, or email notice of noncompliance (with appropriate return receipt) to the recipient. The noncompliance notice must state that:

(1) The recipient is noncompliant with the conditions of their award (reference 2 CFR Part 25);

(2) All payments have been suspended under the award;

(3) The recipient is ineligible to receive any further obligations under existing or future Service awards until they come into compliance;

(4) We reserve the right, without further notice, to convert the suspension to a termination of the award if the recipient does not update their SAM registration or provide an acceptable explanation for the delay within 30 calendar days of receipt of the suspension notice;

(5) The recipient must notify us in writing as soon as they have updated their SAM registration; and

(6) We will lift the award suspension, and the recipient will again be eligible for current and future Federal funding, as soon as their SAM registration is active.

D.  Reject in ASAP any payment requests the recipient submits while on “Agency Review” status (the recipient will have to resubmit the request(s) once the payment block is removed).

E. After the recipient has updated their SAM registration, verify that the recipient’s FBMS vendor record is updated and that the ASAP payment blocks have been removed. FBMS payment blocks should be automatically removed once the vendor’s updated SAM information is interfaced into FBMS.  

F. If within 30 calendar days of receipt of the noncompliance notice the recipient does not notify us that their SAM registration has been updated or provide an acceptable explanation for the delay, we must:

(1) Convert the suspension or sanction(s) to a termination of award,

(2) Withhold any other pending awards that the affected Service program would make to the recipient, and

(3) Send a termination notice to the recipient of these actions. 

5.14 Is the Service responsible for paying interest due because of a payment delay caused by an inactive SAM registration? No. To receive payment, the recipient is responsible for complying with the terms and conditions of the award.

5.15 May the Service reinstate a terminated award? No. Once we terminate an award, we may not reinstate it.

5.16 If, during a period of suspension or termination, a recipient incurs costs authorized under an award, are the costs allowable and eligible for reimbursement? We may reimburse the recipient for allowable and eligible costs during a suspension or termination, but only if:

A. The costs cannot be reasonably avoided;

B. The costs were from obligations the recipient made before the suspension or termination action and not in anticipation of either action. For terminations, the costs must be the type that the recipient could not cancel;

C. The costs would have been allowable if the award were not suspended or terminated; and 

D. We notify the recipient (with appropriate return receipt) through mail, fax, or email that we authorize reimbursement of the costs.