GSA gives the ‘dump DUNS’ movement more hope

By 2018, the General Services Administration will have paid Dun & Bradstreet more than $131 million over the last eight years for access and use of the Data Universal Numbering System (DUNS).

DUNS helps more than 39 agencies uniquely identify contractors with which it does business, according to a November 2016 Congressional Research Service report obtained by the Federation of American Scientists. The 2010 deal also includes access to seven types of software products and 14 data products that enable the government to use the proprietary numbering system for a variety of acquisition-related functions.

This may be the last time D&B receives this type of contract from the government.

GSA added another piece to this two-plus year effort for the government to stop using DUNS after more than 25 years.

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GSA released a request for information Feb. 10 asking for details on other possible options to DUNS.

The agency is asking vendors to answer 20 questions about the three components of entity validation services, including core validation, additional services and a method to determine unique assignment.

Responses to the RFI are due March 13.

“GSA is realizing the current situation is untenable,” said Hudson Hollister, founder and executive director of the Data Coalition and an outspoken critic of the continued use of DUNS by agencies. “There are alternatives that do not require proprietary products to run whole systems of identifying federal contractors. Not only are proprietary identifying codes unnecessary and no longer sensible, with priority identification codes, the system is paid for by the users of the data so that means citizens, researchers and others. They have to pay for every use over and over instead of making payments for the one-time use.”

Hollister and others, such as Sean Moulton, open government program manager at the Project on Government Oversight (POGO), have been pushing GSA to change a practice that began in the early-1990s.

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Moulton said change has been coming, albeit slowly.

“Dun & Bradstreet changed its contract a few months ago to make it easier for agencies to use their data. Agencies can continue to use the data for as long as they want under the terms of the contract,” he said. “Given Dun & Bradstreet started moving down this road, they may continue as GSA describes where they want to go in the RFI. In this case, then it’s about reasonable price and getting them working the way many believe they should. I think the RFI addresses a lot of concerns of those who want D&B out.”

A Dun & Bradstreet spokeswoman said the company remains a trusted source of data about the financial health of companies.

“Dun & Bradstreet continues to work with the GSA and is committed to increasing transparency into government business partners and their activities, making government procurement data smarter, which benefits the American taxpayer,” a company spokeswoman said in an email statement. “We support an open and fair assessment of Entity Validation Providers, and are confident that the value of the DUNS Number remains unmatched.”

Hollister said the need for data transparency goes beyond internal government use. It’s about citizens and others logging onto USASpending.gov and comparing data among contractors or grantees.

“The real benefits of data is if it can be used, reused and compared to each other and at scale that shows what’s going on across the government,” he said. “That’s not happening now.”

The idea to move away from DUNS has been gaining momentum since 2014.

GSA started in 2014 by removing DUNS from the ATOM feed under the Federal Procurement Data System-Next Generation (FPDS-NG). The feed no longer will include the DUNS numbers for the intermediary companies, only the parent company, called the Global Ultimate DUNS Number, and the part of the company subsidiary that won the award from the government. GSA said at the time that the change is necessary because under the contract with Dun & Bradstreet the government doesn’t have access to the other data to make it public.

The Federal Acquisition Regulatory Council issued a proposed rule in November 2015 and then a final rule in September 2016 removing any references to DUNS and establishes definitions of “unique entity identifier,” and “electronic funds transfer (EFT) indicator.”

GSA’s 18F team is developing an identification code that would temporarily help agencies move from the nine-digit DUNS number to another standard.

Hollister said another option is the Legal Entity Identifier (LEI), which the Regulatory Oversight Committee (ROC) established in January 2013. ROC is a group of over 70 public authorities from more than 40 countries.

As of Jan. 4, more than 480,000 entities from 195 countries had obtained LEIs from 29 operational issuers endorsed by the ROC or accredited by the Global LEI Foundation.

“As multiple government agencies require whoever reports to them to get a LEI, then you have incredible network effects. The agency can match filings to multiple regulators around the world,” Hollister said. “When the U.S. government adopts LEI, you can connect filings with GSA to whatever is reported to the Securities and Exchange Commission, if it’s a public company, or reporting to states where the company is incorporated — assuming those adopt LEI too. We no longer will be spending money to match people together, and it means interoperability will be much easier.”

Anthony Scriffignano, the chief data scientist at Dun & Bradstreet, wrote in a Feb. 13 op-ed in The Hill, that there are misconceptions about DUNS and pushed back against the LEI.

“The LEI does not give the government information it needs to evaluate entities entrusted with taxpayer dollars. Financial health information, corporate linkages and company history are also absent. In addition, the LEI shifts the cost burden to government awardees or applicants at more than $200 for initial registration and more than $100 annually for maintenance,” Scriffignano wrote. “With approximately 650,000 businesses registered to do business with the government, the LEI stakeholders stand to gain hundreds of millions in the form of registration costs, fees, and maintenance. The small business community should not have to bear this cost burden to bid for a government contract.”

He added D&B has worked closely with GSA to increase data availability and transparency for the government and the public.

“This helps the GSA optimize federal procurement processes, while ensuring security and integrity of the data. The agreement significantly improves access to the data for analysis and innovation,” Scriffignano wrote.

Moulton and Hollister say should GSA go out with a competitive procurement in late 2017 or early 2018, it may not mean Dunn & Bradstreet will or can’t win the recompete. And even if LEI or a company like LexisNexis decides to bid, agencies still may need D&B’s services.

But at the heart of this issue is the proprietary nature of the current contract, which many say limits data access and transparency and needs to change.

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