1. Home
  2. |Insights
  3. |Goodbye DUNS: System for Award Management Full Transition to New UEI Next Week

Goodbye DUNS: System for Award Management Full Transition to New UEI Next Week

Client Alert | 2 min read | 03.28.22

As of April 4, 2022, the federal government will stop using the Dun & Bradstreet (D&B) Data Universal Number Systems (DUNS) Number to uniquely identify entities and will fully transition to using the Unique Entity Identifier (UEI). All entities will be using the UEI number for SAM and other government systems (including FPDS.gov, eSRS.gov, FSRS.gov, FAPIIS.gov, and CPARS.gov).  DUNS Numbers will no longer be searchable or viewable in SAM.  Those already registered in SAM should not need to take any action.

Purpose

The change is intended to allow for competition in the unique entity validation process by reducing the burden that would be associated with changing the vendors confirming that an entity is unique.  Now SAM will generate the UEI number so it is vendor independent.  The government will be able to compete and award contracts to do the unique entity validation process rather than be obligated to use D&B or any other particular vendor. 

Timeline

The deadline to request a new DUNS Number or update existing entity information at D&B is March 29, 2022 at 5 p.m. EST.  SAM.gov will be down beginning April 1 at 8:00 p.m. EST until no later than April 4 at 9:00 a.m. EST.  During the transition, other government systems will experience intermittent downtime between March 31 and April 3.

Actions

No specific action is required for any entities already in SAM (active or inactive) and moving forward companies will no longer be required to update their DUNS registration (for instance in the event of a name change or address change) before updating SAM.  Those registering in SAM after April 4, 2022 or seeking a UEI after April 4, 2022 will request a UEI through SAM.gov. 

Businesses can view their SAM UEI for each entity registered in SAM by logging into SAM and navigating to the entity’s registration page.  The SAM UEI is in the upper left corner under the DUNS currently, but the DUNS reference should be removed as of April 4, 2022.

SAM.gov has provided FAQs, videos, and an interactive graphic to help stakeholders understand the impacts of the UEI transition, new processes, and required actions.

Insights

Client Alert | 5 min read | 12.12.25

Eleventh Circuit Hears Argument on False Claims Act Qui Tam Constitutionality

On the morning of December 12, 2025, the Eleventh Circuit heard argument in United States ex rel. Zafirov v. Florida Medical Associates, LLC, et al., No. 24-13581 (11th Cir. 2025). This case concerns the constitutionality of the False Claims Act (FCA) qui tam provisions and a groundbreaking September 2024 opinion in which the United States District Court for the Middle District of Florida held that the FCA’s qui tam provisions were unconstitutional under Article II. See United States ex rel. Zafirov v. Fla. Med. Assocs., LLC, 751 F. Supp. 3d 1293 (M.D. Fla. 2024). That decision, penned by District Judge Kathryn Kimball Mizelle, was the first success story for a legal theory that has been gaining steam ever since Justices Thomas, Barrett, and Kavanaugh indicated they would be willing to consider arguments about the constitutionality of the qui tam provisions in U.S. ex rel. Polansky v. Exec. Health Res., 599 U.S. 419 (2023). In her opinion, Judge Mizelle held (1) qui tam relators are officers of the U.S. who must be appointed under the Appointments Clause; and (2) historical practice treating qui tam and similar relators as less than “officers” for constitutional purposes was not enough to save the qui tam provisions from the fundamental Article II infirmity the court identified. That ruling was appealed and, after full briefing, including by the government and a bevy of amici, the litigants stepped up to the plate this morning for oral argument....