Proposed Implementation of the DUNS Number

**as a Unique Identifier for NIH Grantee Organizations**

**Issue:** Currently, NIH employs the IPF number to uniquely identify
grantee organizations that have received awards through extramural
funding agreements. This number, consisting of 7 numeric digits, has
provided a more than adequate degree of source of identifiers since its
inception in the 1960's.

Within the last several years, however, the number of available IPF
combinations is becoming limiting. This limitation coupled with the fact
that the NIH grantee organization population continues to grow has
resulted in recent proposal to increase the IPF number to 8 digits.
Independent of these NIH considerations, other trans-government
electronic grants administration initiatives are now being promoted
requiring the use of universal identifiers for grantee/contractor
organizations who transact grantee business with multiple federal
agencies.

**Recommendation:** These facts strongly suggest a successor to the IPF
number. The Dun and Bradstreet Universal Numbering System (DUNS) number
represents the best available successor. It meets the requirements for a
successor for several reasons:

-   DUNS numbers are of a fixed length and format (9 digits) that has
    been well-documented and publicized to the private, commercial and
    academic business/organizational community. Dun and Bradstreet
    claims that such DUNS numbers have now been created and can be used
    to track more than 62 million companies worldwide. Dun and
    Bradstreet further indicate that the world\'s most influential
    standards-setting organizations, more than 50 global, industry and
    trade associations, and the US Federal Government recognize,
    recommend and/or require the DUNS number in order to form the basis
    for electronic commerce and business performance monitoring.

-   The DUNS numbering system can also accommodate organizations with
    complex organizational hierarchies. Each organization with
    subsidiary components can have unique DUNS numbers for each
    subcomponent. Dun and Bradstreet provides links for the DUNS numbers
    for parents, subsidiaries, headquarters and branches.

-   DUNS numbers can be obtained on-line via the Web, and obtaining the
    number, and later updating information is complete free. The
    procedure is very straightforward, including the creation of a
    business profile. Once the form is completed and submitted to Dun
    and Bradstreet, the information is verified by Dun and Bradstreet
    staff through e-mail notification and follow-up telephone interview.
    Unless the information is personally verified via a telephone call,
    the DUNS number is not assigned. A similar verification process is
    in place to oversee requested changes in the business profile.

-   DUNS numbers can be easily verified on-line via the Web. Any member
    of the public can query the DUNS database for a description of the
    business profile of any organization with a DUNS number. The
    database can be queried with the DUNS number or the name of the
    organization. This feature will facilitate any need to verify
    grantee organizations citing a DUNS number.

**IPF to DUNS Transition:** Currently, when a competitive application is
submitted the Entity Identification Number (EIN) is the identifier
supplied as part of the application that determines the identity of a
grantee organization, provided for as item #12 on the Form 398 face
page. When the application is received in CSR Receipt and Referral, the
EIN on the application is compared to acceptable EIN numbers for that
grantee organization. The internal comparator to the EIN(s) is the IPF
number (one IPF may have many EINs). A correct match results in normal
processing of the application, while any lack of correspondence with the
accepted numbers results in the need for staff to verify the EIN (that
relates to a specific IPF number). Unfortunately, there exists a
considerable number of applications where the EIN does not correspond
(some estimates of \> 10% of applications received). In order for
complete processing of these applications through award, the EIN (IPF)
must be verified by NIH staff, often times via telephone call to the
grantee organization.

A proposal was put forward in 1999 whereby an IPF number was to be
included on the face page of the Form 398 application (within the
applicant organization item) as a means of verification of the
organization distinct from the EIN number. The use of IPF for this
purpose was to have been limited to organizations registered to use the
NIH Commons, since all other organizations would not be aware of the
identity of their IPF number. For organizations who included their IPF
number on the applications, Receipt and Referral staff would know to
overlook any lack of reconciliation of the EIN number.

This potential solution was complicated by the fact that IPF number was
(and still is) not required to submit a paper application, nor is there
any place on the face page of Form 398 to accommodate it. The first
attempt to request inclusion of the IPF number, even among organizations
that had registered for the Commons generated confusion and distress. At
best, this solution was implemented to serve as an interim strategy
until an alternative long-term solution could be put in place.

The alternative solution that would appear more acceptable is to
immediately implement use of the DUNS number on paper applications. The
DUNS number is not currently required, though the Form 398 (revised
4/98) does provide a field for submission of DUNS (face page item #12).
Accordingly, if the DUNS number became a grantee organization unique
identifier, the mechanism for its capture on the Form 398 is OMB
approved and available.

The specific proposal would be for the DUNS number to be the primary
institution identification number. Until such time that all grantee
institutions were using DUNS as an identifier, the current EIN number
comparison would be required. For cases where DUNS was provided the
Receipt and Referral data entry would have to accommodate the DUNS
entry. Once entered, the DUNS could be compared through a lookup table
in the database system to the EIN or IPF number. To prepare for the use
of DUNS on the Commons, during a transitional phase users would be given
the option of either entering the IPF number (which they were given
commensurate with Commons registration), or DUNS. The linking of a DUNS
number with a specific grantee organization would be made part of the
NIH Commons registration process. Once the DUNS was formally
acknowledged it would be stored in IMPAC II as part of the grantee
organization profile. IMPAC II has been designed to carry this data
element. A similar process could allow for the designation of multiple
DUNS numbers per grantee organization, similar to the use of multiple
EINs per grantee organization (i.e. IPF).

With the DUNS formally recognized and stored in IMPAC II, when a Form
398 is received in CSR Receipt and Referral the DUNS number included on
the Form 398 could be compared to the DUNS number that was stored in
IMPAC II. A correct match would result in normal processing of the
application, while any lack of correspondence would result in the need
for staff to verify the DUNS, or alternatively revert back to the EIN
for identity verification.

**Grantee Organization Requirements for Use of DUNS number as Unique
Identifier:** The provision for use of DUNS number by the grantee
organization would require that a one or more DUNS numbers be provided
by the grantee organization to establish how the NIH would recognize
that specific organization. This would require that the DUNS number (or
number[s]{.underline} in the case of large organizations) be part of the
Organizational Profile. The data dictionary for the Organizational
Profile already allows for the capture and storage of DUNS numbers. This
possibility is significant in that it allows the grantee organization to
identify and update, as needed, the DUNS numbers necessary to transact
business and make awards to the specific grantee organization. It would
encourage grantee organizations to maintain the list, in light of the
fact that if the list is inaccurate it could have dire consequences upon
receipt of an award. At the same time, once the original DUNS number/IPF
number verification was made, further changes made by the grantee
organizations should not require additional verification by NIH staff.

In practical terms, DUNS number is currently part of the Organizational
Profile. However, the current implementation only allows for a single
DUNS number. Scripts that support this function would be changed such
that the grantee organization Signing Official who has authority to
alter the Organizational Profile could identify multiple DUNS numbers.
Addition of each new number would require a brief description of the
grantee organization subsidiary, consistent with the Dun & Bradstreet
registration information, to allow for confirmation of identity by NIH
Staff if necessary.

**Implementation of DUNS into the NIH Commons**: Relatively minor
changes in the Commons interfaces would allow for the use of DUNS
number. Currently, the grantee organization user must insert the IPF
number as one of the unique identifiers pursuant to logging onto the NIH
Commons. Commensurate with introduction of DUNS as a unique identifier
on the Form 398, the Commons logon screen would be modified for the user
to provide either the DUNS number for the grantee organization or the
IPF. The fact that the format for the two different numbers is distinct
suggests that the interface could automatically recognize which number
type had been entered, and accordingly perform the appropriate lookup
within the Commons registration/authorized users database.

**Proposed Timeline for Implementation of DUNS:** There are currently
\~170 organizations registered to use the NIH Commons. Technically, the
first step in implementing DUNS would be to make changes to the Commons
interface scripts to allow for the Organizational Profiles of the
registered organizations to add the DUNS numbers. Once available, the
registered organizations could submit DUNS numbers, while at the same
time, any new organizations that began the registration process would be
required to provide DUNS number and description for each subsidiary
organizational component.

Once DUNS numbers and descriptions were available in the Commons
database, numbers could be verified for all organizations already
registered for the Commons. Following verification of Commons registered
organizations, a similar process would become part of the ongoing
Commons registration process. Any new resources that would be necessary
on behalf of IMPAC II staff in order to verify DUNS could be identified
and provided by contract support.

**Process Diagram:**

Grantee Organization NIH Commons IMPAC II