Changes in a General Services Administration (GSA) Registration Process Will Affect Service Providers Participating in the Universal Service Fund (USF) Programs, Starting on November 16, 2022.

All service providers who receive funding from any of the FCC’s USF programs, or the new Affordable Connectivity Program (ACP), are required to have an identification number, called a SPIN, in order to file FCC Form 498 and to receive funds. Among the items formerly required to obtain a SPIN was a so-called DUNS number, a 9-digit number issued by Dun and Bradstreet. This, however, is about to change, as explained in this FCC public notice and summarized below.

GSA’s SAM.gov site, used by government contractors and other parties receiving funds from the federal government, has ceased using DUNS numbers and has replaced them with a new “Unique Entity Identifier” or “UEI.” Service providers will need to have a UEI to file or revise Forms 498 from November 16th onward.

If a provider has already registered in SAM.gov, it has automatically been assigned a UEI. Such a provider should log into its SAM.gov account and go to “Entity” to find its UEI. That UEI should be added to the provider’s Form 498 in E-File.

If a provider is not already registered in SAM.gov, the provider will need to set up a SAM.gov account to register and to obtain a UEI. That process is handled at Login.gov, but it can be reached through the SAM.gov site as well. Once the provider has created an account and signed in at Login.gov, the site should automatically return the provider to SAM.gov to complete a profile.

While it is possible to obtain a UEI without full registration, USF recipients will eventually need to be registered in SAM.gov in order to receive reimbursement from the USF; providers participating in ACP are already required to be registered. For the time being, USF recipients will continue to receive payments, but the Treasury Department will fully transition to using SAM.gov for payment information in 2023. Providers would do well to complete the full registration and to update their SPIN profile in E-File with their UEI as soon as possible.

Please note that registrations in SAM.gov can take up to 6 weeks to be processed. Providers should also note that, although the UEI never expires, the SAM.gov registration does expire and needs to be renewed annually. Upon registering (or logging into an existing account to find the UEI), providers should make note of their registration’s expiration date and plan to renew it in advance of that date each year.

If you have any questions, please contact Christine (Chris) McLaughlin, Esq., at czm@commlawgroup.com, or Michal J. Nowicki, Esq., at mjn@commlawgroup.com.