For prospective government contractors, the first step in this venture is to ensure your business is properly registered. Registration requirements include obtaining a Data Universal Number System (DUNS) number, registration in the System for Award Management (SAM), and obtaining a Commercial and Government Entity (CAGE) code for each unique facility location. Simply put, all three are databases or identifiers that monitor and/or classify businesses based on various data points, such as name, address, and type of products or services the business offers. Government contractors are normally required to obtain all three, and joint ventures (JV) must obtain their own, even if the underlying JV members already have them.
Contractors preparing to do business with the government should first obtain a DUNS number.[1] While the DUNS number is required to do business with the government, it is not maintained by the government.[2] The DUNS number was privately developed by Dun & Bradstreet (D&B) for its credit reporting business and the DUNS database is still managed by D&B. DUNS numbers are required by many businesses and governments as a prerequisite for contracts, grants, and loans. Once an entity obtains the nine-digit unique identifier, it can used to evaluate potential partners in the DUNS database as well as begin the SAM registration process.
Next, FAR 4.1102 requires that prospective contractors be registered in the SAM database at the time an offer or quotation is submitted. Registration can be completed at SAM.gov. After initial registration, the system requires users to annually renew registration data to avoid potential compliance penalties. Users are also required to immediately update any business changes within SAM. In a previous article, we explored the GAO’s treatment of the SAM registration as a minor formality for a contractor that failed to renew its registration properly. However, contractors should be aware of and comply with all relevant maintenance requirements to avoid potential headaches.
Finally, during SAM registration, US-based businesses are assigned a CAGE code, a five-digit identifier. SAM sends the registration to the Defense Logistics Agency (DLA), which issues CAGE codes for US-based entities. For entities located outside the United States and its territories, it is necessary to first obtain a NATO CAGE (NCAGE) code through the NATO Codification System prior to completing the SAM registration process. US CAGE codes obtained after August 26, 2016 must be renewed every five (5) years, while those held prior to that date do not expire.
[1] For more information on the DUNS database, see What is a D-U-N-S Number?, Dun & Bradstreet https://www.dnb.com/duns-number.html (last visited July 4, 2021).
[2] The Office of Management and Budget has indicated that all federal government agencies will migrate from the current DUNS number to a new Unique Entity Identifier (UEI) generated directly by SAM.gov by April 2022.
