This is the accessible text file for GAO report number GAO-12-715R 
entitled 'Government Is Analyzing Alternatives for Contractor 
Identification Numbers' which was released on June 12, 2012. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as 
part of a longer term project to improve GAO products' accessibility. 
Every attempt has been made to maintain the structural and data 
integrity of the original printed product. Accessibility features, 
such as text descriptions of tables, consecutively numbered footnotes 
placed at the end of the file, and the text of agency comment letters, 
are provided but may not exactly duplicate the presentation or format 
of the printed version. The portable document format (PDF) file is an 
exact electronic replica of the printed version. We welcome your 
feedback. Please E-mail your comments regarding the contents or 
accessibility features of this document to Webmaster@gao.gov. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

GAO-12-715R: 

United States Government Accountability Office: 
Washington, DC 20548: 

June 12, 2012: 

The Honorable E. Benjamin Nelson:
Chairman:
Subcommittee on Legislative Branch:
Committee on Appropriations: 

United States Senate: 

Subject: Government Is Analyzing Alternatives for Contractor 
Identification Numbers: 

In 2011, the federal government spent more than $1 trillion on 
contracts and grants. To help manage and oversee these activities, the 
government relies on a number of data systems which are used, for 
example, to advertise solicitations, report awards, and track 
performance. The government needs a way to distinguish between the 
numerous entities with which it does business. For decades, the 
government has relied on Dun & Bradstreet's Data Universal Numbering 
System (DUNS) as a unique identifier. The General Services 
Administration (GSA) contracts with Dun & Bradstreet for use of DUNS 
numbers in governmentwide data systems. Over time, DUNS numbers have 
become embedded in various government data systems and processes, and 
all prospective contractors, grantees, and other federal aid 
recipients generally are required to have a DUNS number in order to do 
business with the government. In recent years, government officials 
have expressed concerns about the rising costs of using DUNS numbers. 
In addition, other companies that offer unique identifier numbering 
systems have questioned why the government will not consider their 
products and services as an alternative to DUNS numbers. 

You asked us to review the federal government's use of DUNS numbers. 
In response, we examined (1) how the government currently contracts 
for and uses DUNS numbers; (2) the challenges posed by the 
government's use of DUNS numbers; and (3) steps GSA has taken to 
mitigate these challenges. To address these objectives, we analyzed 
GSA documents such as analyses of alternatives and contracts and 
interviewed officials from GSA, other agencies, and Dun & Bradstreet. 
We also interviewed officials from companies that compete with Dun & 
Bradstreet in commercial markets. 

We conducted this performance audit from January 2012 to June 2012 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Results in Brief: 

In recent years, the government's reliance on DUNS numbers has 
increased significantly. There has been a dramatic increase in the 
number and types of entities that are required to have DUNS numbers to 
do business with the government. GSA also has expanded the level of 
business information services that it acquires from Dun & Bradstreet. 
These services include data verification and monitoring as well as 
corporate linkage information to support enhanced reporting 
capabilities. As GSA has increased its use of the DUNS number and 
business information services, its costs have increased from about $1 
million in 2002 to approximately $19 million per year under the 
current contract. The current contract for DUNS numbers is a sole-
source contract awarded to Dun & Bradstreet in 2010 for a 3-year base 
period with options for 5 additional years--the contract now totals up 
to $154 million. 

There are several challenges associated with GSA's contract for unique 
identification numbers. GSA believes that Dun & Bradstreet effectively 
has a monopoly for government unique identifiers that has contributed 
to higher costs. This effective monopoly results in part from 
government regulations and directives that require contractors, 
grantees, and other entities seeking to do business with the 
government to obtain a DUNS number. Also, due to the proprietary 
nature of DUNS numbers, Dun & Bradstreet has placed restrictions on 
how GSA can use DUNS numbers. This limits the purposes for which the 
government can use the data and hampers the ability to switch to a new 
numbering system. Dun & Bradstreet's competitors have raised concerns 
regarding the government's use of DUNS numbers as its unique 
identification number. These companies believe that the integral role 
of DUNS numbers in government systems has provided Dun & Bradstreet 
with unfair advantages in the government or commercial markets for 
business data. Other organizations have expressed concerns about the 
government's use of DUNS numbers as well. For example, one 
organization noted that DUNS numbers are not subject to transparency 
requirements such as Freedom of Information Act requests so it is 
difficult to determine independently the accuracy or comprehensiveness 
of DUNS information. 

To address concerns about the high costs and proprietary restrictions 
associated with the government's use of DUNS numbers, GSA recently 
began an analysis of alternatives for unique numbering systems. In its 
ongoing analysis, GSA has conducted market research and plans to 
conduct a cost-benefit analysis and feasibility study for alternatives 
to using DUNS numbers by September 2012. GSA has concluded that it is 
not in the best interests of the government to change from one 
proprietary number to another. The agency is therefore evaluating the 
advantages and disadvantages of replacing DUNS numbers with a 
government-owned numbering system. GSA also will be considering a 
hybrid approach utilizing both DUNS numbers and a government-owned 
numbering system, which could be a viable alternative. A key factor in 
deciding whether to replace DUNS numbers in government data systems is 
the cost of switching. In the event of a change, GSA and dozens of 
other agencies would have to modify their data systems, replace all 
DUNS-related data in those systems, and update policies and procedures 
that refer to DUNS numbers. GSA officials have said switching costs 
could be substantial and, while they have outlined steps for capturing 
costs, they are still developing their methodology for estimating 
these costs. Meanwhile, even as GSA continues using DUNS numbers, the 
agency may be able to ease current restrictions on their use, such as 
the requirement to delete associated DUNS data when the contract with 
Dun & Bradstreet ends. We are recommending that GSA initiate 
negotiations with Dun & Bradstreet to that end. GSA agreed with our 
recommendation. 

Background: 

Governmentwide acquisition systems, finance systems, and other data 
systems depend on the ability to assign a unique identification number 
to businesses and other organizations seeking to do business with the 
government. The federal government has contracted with Dun & 
Bradstreet since 1978 to provide DUNS identification numbers for all 
government contractors. A DUNS number is a unique nine-digit number 
that is assigned to every business entity in Dun & Bradstreet's global 
business database, which according to Dun & Bradstreet contains more 
than 166 million records. Many businesses have multiple DUNS numbers 
since Dun & Bradstreet assigns a number to each physical location of 
an organization (such as branches, divisions, and headquarters). In 
addition to the right to use DUNS numbers as a unique identification 
number, GSA also contracts with Dun & Bradstreet to provide business 
information and related services on all existing and potential 
government contractors and awardees. This information is linked to the 
business entity through the DUNS number. The DUNS number and 
associated business information are owned and controlled by Dun & 
Bradstreet, but licensed to the government to be used for selected 
acquisition purposes. 

The federal government began using DUNS numbers in the 1970s to 
identify and track contractors. During the late 1980s and early 1990s, 
the government replaced the DUNS number and established its own 
database of Contractor Establishment Code (CEC) numbers. The 
government contracted with Dun & Bradstreet to operate and maintain 
this database. In 1996, the government made a determination to replace 
the CEC numbers and use the commercially available DUNS number to 
fulfill its needs; a Federal Acquisition Regulation (FAR) interim rule 
was issued to implement this determination.[Footnote 1] Government 
officials said the decision was based on several factors, most notably 
that the DUNS number was widely used and accepted, both domestically 
and internationally, and that the DUNS number was viewed as the only 
reliable mechanism for cross-walking to other numbering systems. In 
1998, the FAR was amended with a final rule to replace the CEC with 
the DUNS number as the means of identifying contractors in the 
government's main reporting data system, the Federal Procurement Data 
System (FPDS).[Footnote 2] In 2003, another amendment to the FAR 
specified that contractors must obtain and submit a DUNS number in 
order to register in the Central Contractor Registration (CCR), a data 
system in which all prospective contractors generally must register to 
be eligible for government contracts.[Footnote 3] 

GSA is the agency responsible for managing the Dun & Bradstreet 
contract. That contract provides the rights to use DUNS numbers in 
CCR, the Federal Procurement Data System-Next Generation (FPDS-NG), 
and several other governmentwide acquisition data systems. In 2002, 
the contract became part of the Integrated Acquisition Environment 
(IAE), a GSA-led initiative to bring together different acquisition 
data systems. IAE consists of several data systems that support 
actions integral to the acquisition process, such as posting 
contracting opportunities, registering prospective contractors, 
assessing contractor performance, and reporting contract actions. 
[Footnote 4] GSA uses memorandums of understanding with the 24 
departments and agencies now covered by the Chief Financial Officers 
Act of 1990 to collect funding contributions, which pay for the 
development, operations, and maintenance of IAE's portfolio, including 
the Dun & Bradstreet contract. GSA is currently working to consolidate 
its portfolio of data systems into one single system known as the 
System for Award Management (SAM). The first phase of SAM will 
incorporate the functionality of three IAE data systems--CCR, the 
Excluded Parties List System (EPLS), and the Online Representations 
and Certifications Application (ORCA). GAO recently reported on GSA's 
progress in implementing SAM and found that higher than anticipated 
costs and constrained resources have resulted in delays and pose a 
risk to the future viability of the project.[Footnote 5] In response 
to our recommendations, GSA is currently reassessing its approach to 
developing and implementing SAM. 

The DUNS Number Has Become an Increasingly Integral Component in How 
Government Data Systems Operate: 

In recent years, the government's reliance on DUNS numbers has 
increased and they have become an integral component in how government 
data systems operate. For instance, there has been a dramatic increase 
in the number and type of entities that are required to have DUNS 
numbers to do business with the government. When the DUNS number was 
incorporated into the FAR as a final rule in 1998, only prospective 
contractors were required to obtain DUNS numbers. In 2003, the Office 
of Management and Budget (OMB) issued guidance that also required 
grant and cooperative agreement applicants to obtain DUNS numbers. 
[Footnote 6] OMB expanded this policy in 2008 when it required DUNS 
numbers for recipients of loans and other types of financial 
assistance.[Footnote 7] In January 2006, there were 403,000 
contractors registered in CCR. There are approximately 625,000 
entities currently registered in CCR, including contractors, grantees, 
and other federal assistance recipients and each had to obtain a DUNS 
number in order to register. 

In addition to an increase in the number of entities required to 
obtain a DUNS number, the level of business information services that 
GSA acquires from Dun & Bradstreet also expanded. These services 
include verifying basic information such as an entity's name and 
address, providing corporate linkages, and monitoring changes to 
entity names or corporate ownership.[Footnote 8] Previously, GSA's 
contract with Dun & Bradstreet only provided business information 
services for the acquisition community and the IAE systems associated 
with it. This changed when the Federal Funding Accountability and 
Transparency Act of 2006 (Transparency Act) required OMB to ensure the 
existence and operation of a website at which the public could search 
certain data about government financial awards, including contracts, 
grants, and loans.[Footnote 9] Among the required searchable elements 
for each award is a unique identifier of the entity receiving the 
award and of the parent entity of the recipient. OMB chose the DUNS 
number to fulfill the unique identifier requirement. With this action 
the number of entities for which Dun & Bradstreet provides corporate 
linkage information expanded from just contractors to all recipients 
of federal awards. Later, in 2010, OMB also began requiring all 
federal awardees to register in CCR, which increased the level of 
business verification information provided by Dun & Bradstreet. 
[Footnote 10] Finally, the American Recovery and Reinvestment Act of 
2009 (Recovery Act) temporarily increased the number of entities 
receiving federal awards, thereby increasing the number of entities 
registering in CCR for which the government collected DUNS 
information.[Footnote 11] 

The DUNS number has also become embedded in agencies' internal data 
systems and is used to support other agency missions. IAE officials 
report that most of the more than 60 agencies that use IAE acquisition 
systems rely on DUNS numbers in their internal financial and contract 
writing systems. For example, CCR contains information on contractors, 
including DUNS numbers and entity name and address, which agencies 
download and use to make payments. The DUNS number has become so 
integrated and common in government financial systems that GAO 
recommended its use in a report that provided guidelines on properly 
functioning financial processes.[Footnote 12] In addition, some 
agencies have separate contracts with Dun & Bradstreet for DUNS 
numbers and business information services to support their specific 
missions. GSA officials said that agencies may use Dun & Bradstreet 
data from CCR or other IAE systems for acquisition purposes. However, 
if they need DUNS related information or services that are not covered 
by the GSA contract, they must enter into their own contract with Dun 
& Bradstreet. For instance, the Small Business Administration has a 
contract with Dun & Bradstreet to use DUNS numbers and related data to 
help provide financial oversight of its loan programs. Other agencies 
have their own contracts with Dun & Bradstreet for data used for visa 
fraud detection, financial fraud detection, and air cargo risk 
management. 

As use of the DUNS number and business information services has 
increased, GSA's costs have increased as well. Between 2002 and 2004, 
the cost of the DUNS number contract was tied to the number of CCR 
registrants and cost about $1 million per year. In response to the new 
demands for business information services required by the Transparency 
Act, GSA signed a contract with Dun & Bradstreet in 2007 that changed 
the pricing structure from a per-transaction model, where costs were 
based on the number of CCR registrants, to an "enterprise" model where 
the government is provided with access to Dun & Bradstreet business 
data for a fixed price. GSA officials told us that the requirements in 
the Transparency Act to make corporate linkage information available 
on a public website also resulted in higher prices since Dun & 
Bradstreet needed to be compensated for making proprietary information 
publicly accessible. While GSA believes this pricing structure is more 
cost effective given the new requirements, it has resulted in a large 
increase in payments to Dun & Bradstreet, which average $19 million 
per year under the current contract (see figure 1). There was a 
temporary drop in payments in fiscal year 2011 because GSA modified 
its contract with Dun & Bradstreet to defer payments to later years. 
Under the terms of the contract, GSA had been scheduled to pay Dun & 
Bradstreet $18 million in August 2011. In order to support efforts 
related to the development of SAM, GSA negotiated two modifications to 
the contract that allowed GSA to defer $14 million from fiscal year 
2011 to fiscal year 2012. This action was a result of the fiscal 
challenges GSA has faced as it consolidates its portfolio of data 
systems into its new unified data system, SAM. 

Figure 1: IAE Payments to Dun & Bradstreet by Fiscal Year: 

[Refer to PDF for image: line graph] 

Fiscal year: 2002; 
IAE Payment: $734,560. 

Fiscal year: 2003; 
IAE Payment: $1,800,000. 

Fiscal year: 2004; 
IAE Payment: $1,100,000. 

Fiscal year: 2005; 
IAE Payment: $6,196,601. 

Fiscal year: 2006; 
IAE Payment: $10,453,486. 

Fiscal year: 2007; 
IAE Payment: $10,500,000. 

Fiscal year: 2008; 
IAE Payment: $15,319,650. 

Fiscal year: 2009; 
IAE Payment: $16,685,537. 

Fiscal year: 2010; 
IAE Payment: $27,008,787. 

Fiscal year: 2011; 
IAE Payment: $5,603,000. 

Fiscal year: 2012; 
IAE Payment: $25,850,132. 

Fiscal year: 2013; 
IAE Payment: $22,469,257. 

Fiscal year: 2014; 
IAE Payment: $16,334,933. 

Fiscal year: 2015; 
IAE Payment: $16,988,331. 

Fiscal year: 2016; 
IAE Payments: $17,667,864. 

Fiscal year: 2017; 
IAE Payment: $18,374,578. 

Fiscal year: 2018; 
IAE Payment: $12,572,080. 

Source: GAO analysis of GSA information. 

Note: The dotted line (FY 2013-FY 2018) indicates the future payment 
schedule identified in the Dun & Bradstreet contract. Also, the 
final option ends on June 29, 2018, so the fiscal year 2018 payment 
does not cover the final 3 months of the fiscal year. 

[End of figure] 

The current contract, which was awarded in 2010 for up to 8 years (3-
year base period plus options for 5 additional years) and is now worth 
up to $154 million, is the latest in a series of sole-source, multiple-
year contracts awarded to Dun & Bradstreet. GSA officials told us the 
DUNS contracts have been sole-source awards because of the FAR 
requirement that all government contractors obtain a DUNS number, and 
because they have been unable to identify an acceptable alternative. 
In addition to assigning DUNS numbers and providing related services, 
Dun & Bradstreet operates a help desk to support current and new 
registrants and carries out special analyses and ad hoc projects. GSA 
officials reported that assigning DUNS numbers and the help desk 
represent about 20 percent of the contract price. The remaining 80 
percent of the price primarily pays for the business verification and 
corporate linkage information that Dun & Bradstreet provides. 

The Government Faces Several Challenges Associated with Using DUNS 
Numbers: 

The government faces several challenges associated with GSA's contract 
for unique identification numbers. GSA believes that Dun & Bradstreet 
effectively has a monopoly that has contributed to higher costs. This 
effective monopoly results in part from the FAR requirement and OMB 
directives that require all contractors, grantees, and other entities 
seeking to do business with the government to acquire a DUNS number. 
GSA officials have said that as long as the FAR requirement is in 
place they must use the DUNS number and cannot hold a competition for 
unique identification numbers. GSA officials said that the current 
sole-source environment results in higher prices to the government, 
and that a competitive acquisition likely would result in lower prices 
to GSA. They also expressed concern that Dun & Bradstreet's prices may 
continue to rise as the government's use of its services continues to 
expand. Additionally, members of the Acquisition Committee for e-Gov 
(ACE), IAE's governance committee, have also questioned the high costs 
for DUNS numbers as Dun & Bradstreet's contract is IAE's largest 
expense.[Footnote 13] In response to cost concerns, GSA officials held 
discussions with a Dun & Bradstreet competitor in 2008 to help gauge 
the reasonableness of the prices that Dun & Bradstreet charged. GSA 
officials found that Dun & Bradstreet's prices were relatively high 
compared to this competitor, which offered another proprietary 
product, and the officials said they used this information to 
negotiate a better price from Dun & Bradstreet for the contract 
awarded in 2010. GSA officials said they negotiated a 25 percent 
reduction in prices in exchange for a longer contract length and 
changes in how GSA administers the contract. However, despite the 
lower prices, GSA officials are still concerned with the high costs 
associated with the use of DUNS numbers relative to other IAE program 
costs. 

Another challenge the government faces involves the proprietary 
limitations that Dun & Bradstreet has placed on GSA's use of DUNS 
numbers. Specifically, GSA's contract with Dun & Bradstreet limits how 
and where Dun & Bradstreet data can be used. For example, the contract 
specifies that Dun & Bradstreet data may only reside in IAE data 
systems and on federal agency acquisition systems, and can be used 
only for acquisition purposes. Any other uses or disclosure of data 
outside of the contract scope and licensing terms, even if the 
activity is government related, would require either a contract 
modification or a new separate contract. In at least one case, this 
has hampered the government's ability to effectively use DUNS numbers. 
In 2009 Congress requested that the Department of Defense (DOD) report 
on the total value of DOD contracts entered into with contractors that 
have been indicted for, settled charges of, or had been fined or 
convicted of fraud in connection with any contract entered into with 
the federal government over the past 10 years.[Footnote 14] In 
responding to this directive, DOD obtained fraud case data from the 
Department of Justice that did not contain DUNS numbers. DOD used the 
company names to search for contract obligation data in FPDS-NG. 
Without DUNS numbers and their associated corporate linkage 
information, however, DOD was unable to identify the parent company of 
all offending companies and could not capture all the obligation data. 
DOD was unable to use corporate linkage information since this use of 
data fell outside the scope of GSA's contract with Dun & Bradstreet. 
[Footnote 15] 

Additionally, there are other restrictions in the contract that could 
cause challenges for the government if it were to change to an 
alternative numbering system. According to GSA, the contract specifies 
that the government would have to delete certain Dun & Bradstreet 
provided data from its databases at the end of the GSA contract. GSA 
officials said that under the terms of the contract, GSA is not 
required to delete the DUNS numbers, but could have to purge 
associated data. This would include data elements such as business 
name and address.[Footnote 16] GSA officials said this would apply to 
the IAE systems in addition to agency acquisitions systems if GSA 
ended the Dun & Bradstreet contract and moved to a new numbering 
system. Given the widespread use of DUNS numbers and associated data 
in government data systems, this could be very disruptive. 

Dun & Bradstreet's competitors have raised concerns regarding the 
government's use of DUNS numbers as its unique identification number. 
We spoke with three companies that compete in the commercial market 
with Dun & Bradstreet and each of these companies raised issues that 
they believe provide Dun & Bradstreet unfair advantages in the 
government or commercial markets for business data. For instance, one 
company noted that some federal agency officials have interpreted the 
DUNS requirement in the FAR to mean that DUNS numbers are required in 
other contexts as well. The company provided several examples, one of 
which was a solicitation to create a new agency-specific database that 
required the database to use DUNS numbers. Although this solicitation 
was using full and open competition, the company told us that 
including the DUNS number requirement in the solicitation ensured that 
only Dun & Bradstreet could qualify for the contract. Additionally, 
the same company also pointed out that the requirement to register in 
CCR means that thousands of companies provide Dun & Bradstreet with 
their business information, while Dun & Bradstreet's competitors have 
to discover this information using their own resources. Because of 
this, the competitor believes that Dun & Bradstreet has a monopoly for 
government identifiers which gives Dun & Bradstreet an unfair 
advantage in the competitive commercial market for business data as 
well. 

Organizations concerned about transparency in government activities 
also have raised concerns related to using a numbering system that 
does not enable the public to fully track entities doing business with 
the government. For example, in a 2008 letter to OMB, the National 
Association of State Auditors, Comptrollers, and Treasurers (NASACT) 
noted that Dun & Bradstreet is not accountable to any government 
authority, yet DUNS numbers play a vital role in providing a 
governmentwide identifying system. NASACT also cited data reliability 
concerns with Dun & Bradstreet's process for assigning DUNS numbers to 
state government agencies and other entities. OMB Watch, a nonprofit 
organization, also has criticized the lack of transparency associated 
with using the DUNS numbers. For example, the organization noted that 
DUNS numbers are not subject to transparency requirements such as 
Freedom of Information Act requests so it is difficult to determine 
independently the accuracy or comprehensiveness of DUNS information. 
OMB Watch encouraged the government to develop its own unique 
identification number rather than remain dependent on a privately 
owned system that is inaccessible to the public. 

GSA Is Analyzing Alternatives to Mitigate DUNS Challenges, but Results 
Yet to Be Determined: 

Concerns about the high costs associated with the government's use of 
DUNS numbers have led GSA to consider using alternative unique 
numbering systems. In 2009, GSA issued a sources sought notice to 
measure the interest and availability of companies capable of 
providing a system for unique identification numbers.[Footnote 17] GSA 
officials did not know whether any companies other than Dun & 
Bradstreet offered unique identifiers and related services that were 
comparable to DUNS numbers. GSA received two responses to its 2009 
sources sought notice (and a third from Dun & Bradstreet) and 
determined that one of the companies was a viable competitor to Dun & 
Bradstreet. However, in their evaluation of the responses, GSA 
officials concluded that they could not conduct a competition for 
unique identifiers until the FAR was modified to remove the DUNS 
requirement. These officials recommended that GSA initiate a FAR 
change and then conduct a full and open competition for unique 
identifiers once the change had been completed. GSA officials said 
they developed a proposal to change the FAR, but the Federal 
Acquisition Regulatory Council recommended suspending the effort to 
change the FAR until the completion of a comprehensive cost and 
schedule analysis.[Footnote 18] GSA had not evaluated the costs of 
changing numbering systems at that time although some agencies had 
voiced concerns that switching costs could be significant. Shortly 
after the FAR change was put on hold, GSA awarded the current sole-
source contract to Dun & Bradstreet in 2010. In explaining its 
rationale for awarding a sole-source contract, the agency noted that 
the FAR required the use of DUNS numbers and Dun & Bradstreet was the 
only source of DUNS numbers. 

In 2011, GSA initiated another effort to identify possible 
alternatives for unique identification numbers and expects to issue a 
report on its findings and recommendations by September 2012. This 
latest effort consists of a sources sought notice as well as a cost-
benefit analysis and feasibility study of alternative approaches to 
acquiring numbering systems. The different approaches that GSA has 
considered include: 

* Continue to use DUNS numbers and services, 

* Conduct a full-and-open competition, if the sources sought 
assessment identifies potential competitors, 

* Change to a non-proprietary solution, either using a non-proprietary 
numbering system or obtaining services from one or more vendors, and: 

* Change to a government-owned number and obtain data services from 
one or more vendors. 

GSA issued a sources sought notice in October 2011 and received six 
responses, including one from Dun & Bradstreet. Based on the 
responses, GSA determined that there are potential competitors for 
unique identification numbers. However, GSA has ruled out conducting a 
full and open competition for numbering systems after concluding that 
it is not in the government's best interest to move from one 
proprietary numbering system (DUNS numbers) to another one. GSA 
officials said the additional costs and data system disruptions 
encountered each time it changed numbering systems would at least 
partially offset any potential cost savings achieved by introducing 
competition. GSA also has ruled out changing to a non-proprietary 
numbering system because none of the sources sought responses included 
a non-proprietary alternative.[Footnote 19] 

GSA is currently considering two strategies as part of its analysis--
continuing to use DUNS numbers or changing to a government-owned 
numbering system. The first option is to continue the current Dun & 
Bradstreet contract "as-is." However, this alternative does not 
address a key concern raised about the use of DUNS numbers. The Dun & 
Bradstreet contract limits the purposes for which the government may 
use DUNS information and according to GSA requires the government to 
delete Dun & Bradstreet data such as business name and address when 
the contract ends. Two of Dun & Bradstreet's competitors indicated 
that they do not require that clients delete their data when a 
contract ends, but it is unclear what they would offer in a formal 
contract. Continuing to use DUNS numbers does not prevent GSA from 
taking steps to ease some of the restrictions that Dun & Bradstreet 
has placed on the government's use of DUNS information. GSA officials 
said that simply by asking Dun & Bradstreet for a discount they were 
able to negotiate a significant price reduction for the current 
contract. However, they said they did not raise the issue of expanding 
the government's data rights during negotiations. 

GSA is also considering changing to a government-owned numbering 
system. There are several possible government-owned numbers that GSA 
could use, such as SAM numbers. SAM is scheduled to begin operation in 
2012 and once operational, contractors, grantees and other entities 
seeking to do business with the government will have to register in 
SAM, which will replace CCR. As entities register, they will 
automatically be assigned a SAM number. The SAM number was not 
initially intended to serve as a unique identifier and like other 
government-owned numbers, GSA would have to add capability to make 
them viable alternatives to DUNS numbers. For example, SAM does not 
currently have a registration system to collect name, address, and 
other information on businesses and other entities so a registration 
system would have to be created. Similarly, SAM numbers would not 
provide corporate linkage information or the ability to verify or 
monitor data so GSA would have to add those capabilities. GSA 
officials said that if they were to change to government-owned number, 
they would likely award one or more competitive contracts to manage 
the numbering system and provide services similar to those that Dun & 
Bradstreet currently provides. They said that other adjustments and 
associated costs, both internal to the government and otherwise, could 
be involved as well. They also said that there could be other 
solutions not yet identified. 

Although there may be numerous benefits to changing to a government-
owned numbering system, including long-term cost savings, unlimited 
data rights, and greater transparency, the switching costs from using 
DUNS numbers could be prohibitively high. We asked GSA whether it 
would be feasible to use a hybrid approach in which GSA would continue 
to use DUNS numbers in addition to a government-owned number for an 
extended period of time. Under this alternative, GSA would continue 
its current contract with Dun & Bradstreet while it phases in the use 
of a government-owned number. Entities registering in SAM would have 
both a DUNS number and a number from the new system. Once the new 
numbering system is fully established, GSA would have the option of 
phasing out DUNS numbers. A hybrid approach could avoid or defer a 
significant portion of the switching costs, minimize disruptions to 
agencies, and better position the government to introduce competition 
for unique identifiers in the future. GSA officials agreed that a 
hybrid approach was a viable alternative and now are considering it as 
part of the analysis of alternatives. 

GSA officials are planning to assess the feasibility of the 
alternatives and then begin coordinating with federal agencies to 
develop a cost estimate for changing numbering systems. Changing to a 
new numbering system would include costs associated with the following 
actions: 

* Adding capabilities to a government-owned number. As noted above, 
changing to a government-owned number would require GSA to establish a 
registration process and add the ability to provide corporate linkage 
information and add data verification and monitoring capabilities. 

* Modifying data systems. To accommodate a new number, GSA and other 
agencies would have to change the name of data fields and possibly add 
new data fields or modify the format of the existing DUNS field in 
their data systems. For example, DUNS numbers are numeric whereas SAM 
numbers are alpha-numeric and therefore may not be compatible with 
current DUNS data fields. 

* Replacing DUNS information with information from a new numbering 
system. Changing numbering systems could require agencies to delete 
DUNS information, including contractor name and address, from their 
data systems and replace it with information from the new numbering 
system. This process could be complicated by the data restrictions in 
GSA's contract with Dun & Bradstreet. GSA officials said that they are 
uncertain whether the terms of the contract with Dun & Bradstreet 
would allow the government to use the existing DUNS information to 
transition to a new numbering system. If GSA is unable to use DUNS 
information for transition purposes, it would have to match the new 
numbering system to existing contractor information without the 
benefit of using the contractor's name or address. GSA is planning to 
discuss with Dun & Bradstreet what rights the government would have in 
the event of a transition. 

* Updating policies and procedures. GSA would have to modify the FAR 
to remove the DUNS requirement and agencies would have to update their 
FAR supplements. Agencies would also have to update acquisition-
related policies, procedures, and documents that refer to DUNS numbers. 

GSA provided documents to us reflecting some initial steps it will 
take to assess switching costs. A GSA official said the agency plans 
to estimate the costs of changing its own internal systems and then 
extrapolate the costs to other agencies. GSA's analysis is still 
ongoing. The agency has identified potential cost drivers, but it is 
still developing a methodology for quantifying them. Determining an 
accurate estimate of switching costs could be difficult due to the 
number of agencies and data systems involved. GSA identified 
approximately 80 data systems that contained DUNS information 
extracted from CCR and would therefore have to be modified in the 
event of a transition to a new numbering system. There are also many 
more subsystems within agencies that could potentially be affected by 
changing DUNS numbers. GSA is still determining how best to capture 
switching costs associated with these agency data systems. 

Conclusions: 

Rising costs, restrictions on the government's data rights, and a lack 
of competition have raised concerns about the government's use of DUNS 
numbers as a unique identifier. Those concerns have prompted GSA, not 
for the first time, to analyze options for changing how it acquires 
unique identifiers. GSA has a difficult task ahead as it evaluates the 
legal, contractual, and technical challenges associated with changing 
identification numbering systems. GSA is still developing its 
methodology for conducting its analysis so it is too soon to comment 
on how comprehensive GSA's analysis will be. Further, choosing an 
alternative may only be the first step in a process that GSA expects 
could take years to complete. If GSA decides to change how it acquires 
unique identifiers, it would need to develop a detailed plan for 
executing the transition. GSA would need to develop an acquisition 
plan for acquiring additional services, plan and budget for any 
additional resources necessary to effect the change, and define the 
roles and responsibilities for numerous stakeholders. If GSA is able 
to successfully complete its analysis and a transition plan, it may be 
able to mitigate the challenges posed by the government's use of DUNS 
numbers as a unique identifier. Alternatively, the analysis may 
demonstrate that GSA's current approach is the best for the government. 

Meanwhile, there may be an opportunity to negotiate better terms for 
the government under the existing arrangement with Dun & Bradstreet. 
Even as GSA continues to use Dun & Bradstreet as the provider of 
unique identifier services, the agency may be able to ease the current 
contractual restrictions on the use of DUNS numbers, such as the 
requirement to delete data at the end of the contract, by bringing 
these provisions more in line with prevailing industry practices. 

Recommendation for Executive Action: 

To ensure that government agencies have improved access to information 
needed to effectively fulfill their missions, we recommend that the 
Administrator of GSA initiate discussions with Dun & Bradstreet on 
ways to reduce current restrictions on the use of DUNS numbers. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to GSA. The agency agreed with our 
recommendation and indicated it would take appropriate action. GSA's 
written comments appear in enclosure I. GSA also provided technical 
comments that we incorporated as appropriate. 

We are sending copies of this report to other interested congressional 
committees, the Acting Administrator of General Services, and the 
Office of Management and Budget. In addition, this report will be 
available at no charge on the GAO website at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have questions about this report, please contact 
me at (202) 512-4841 or by email at woodsw@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. Key contributors to this report were 
John Oppenheim, Assistant Director; E. Brandon Booth; Jeffrey Sanders; 
Benjamin Shattuck; Deanna Laufer; and Marie Ahearn. 

Signed by: 

William T. Woods:
Director:
Acquisition and Sourcing Management: 

Enclosures - 1: 

[End of section] 

Enclosure I: Comments from the General Services Administration: 

GSA: 
The Administrator: 
U.S. General Services Administration: 
1275 First Street, NE: 
Washington, DC 20417: 
Telephone: (202) 501-0800: 
Fax: (202) 219-1243: 

June 8, 2012: 

The Honorable Gene L. Dodaro: 
Comptroller General of the United States: 
U.S. Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Dodaro: 

The U.S. General Services Administration (GSA) appreciates the 
opportunity to review and comment on the draft report, "Government is 
Analyzing Alternatives for Contractor Identification Numbers" (GAO-12-
715R). The U.S. Government Accountability Office (GAO) recommends that 
GSA initiate discussions with Dun & Bradstreet on ways to reduce 
current restrictions on the use of DUNS numbers, so as to ensure that
Government agencies have improved access to information needed to 
effectively fulfill their missions. 

We agree with the recommendation and will take appropriate action. 
GSA, as the GAO report discusses, has been conducting an analysis of 
alternatives to the use of the Dun & Bradstreet DUNS entity unique 
identifier and we expect to complete our analysis in September. The 
objective of the analysis is to identify feasible alternatives to 
awarding the current sole source contract for Dun & Bradstreet’s 
proprietary services and to identify whether the current contract path 
or an alternative solution is the most cost-effective option 
available, given the identified risks, particularly very large switching
costs, and given federal requirements for transparency. 

If you have any additional questions or concerns, please do not 
hesitate to contact me or Ms. Kathleen Turco, Associate Administrator, 
Office of Governmentwide Policy, at (202) 501-8880. 

Sincerely, 

Signed by: 

Dan Tangherlini: 
Acting Administrator: 

cc: William T. Woods: 

[End of section] 

Footnotes: 

[1] 61 Fed. Reg. 67,412 (Dec. 20, 1996). 

[2] 63 Fed. Reg. 9,049 (Feb. 23, 1998). The final rule is currently 
implemented at FAR § 4.605(b) which identifies the DUNS number as the 
Contractor Identification Number for reporting the successful offeror 
in the Central Contractor Registration database. 

[3] FAR § § 4.1102; 52.204-7. Exceptions to registration in the CCR 
database for prospective offerors are in FAR 4.1102 

[4] The nine systems of IAE include Federal Business Opportunities 
(FedBizOpps), FPDS-NG, Wage Determinations OnLine (WDOL), Past 
Performance Information Retrieval System (PPIRS), Excluded Parties 
List System (EPLS), Central Contractor Registration (CCR), Federal 
Agency Registration (FedReg), Electronic Subcontract Reporting System 
(eSRS), and Online Representations and Certifications Application 
(ORCA). 

[5] GAO, Effort to Consolidate Government Acquisition Data Systems 
Should Be Reassessed, [hyperlink, 
http://www.gao.gov/products/GAO-12-429] (Washington, D.C.: March 2012) 

[6] Office of Management and Budget Memorandum M-03-16, "OMB Issues 
Grants Management Policies" (July 15, 2003); Use of a Universal 
Identifier by Grant Applicants, 68 Fed. Reg. 38,402 (June 27, 2003) 
Grantees were not required to register in CCR at that time, but were 
directed to do so by OMB in August 2010. OMB Memorandum, "Open 
Government Directive--Federal Spending Transparency and Subaward and 
Compensation Data Reporting" (Aug. 27, 2010); Financial Assistance Use 
of Universal Identifier and Central Contractor Registration, 75 Fed. 
Reg. 55,671 (Sept. 14, 2010). 

[7] OMB Memorandum M-08-19, "Authority to Collect DUNS Number to Meet 
Requirements of the Federal Funding Accountability and Transparency 
Act of 2006" (May 30, 2008). 

[8] The corporate family information allows the government and the 
public, through the Federal Procurement Data System-Next Generation 
(FPDS-NG) and USAspending.gov, to aggregate data to show the total 
amount of contracts or awards a company has received. The linkage 
information also enhances the effectiveness of the Excluded Parties 
List System (EPLS), the list designed to identify individuals and 
entities that have been debarred or suspended from obtaining 
government awards. 

[9] Pub. L. No. 109-282, as amended by Pub. L. No. 110-252 § 6202. The 
website became USAspending.gov. 

[10] 75 Fed.Reg. 55,671 (Sept. 14, 2010). 

[11] Pub. L. No. 111-5. 

[12] GAO, Core Financial System Requirements: Checklist for Reviewing 
Systems under the Federal Financial Management Improvement Act, 
[hyperlink, http://www.gao.gov/products/GAO-05-225G] (Washington, 
D.C.: February 2005). 

[13] The ACE is a subcommittee of the Chief Acquisition Officer's 
Council which was established to provide a senior level forum for 
monitoring and improving the federal acquisition system. 

[14] Explanatory Statement of the House of Representatives 
Subcommittee on Defense Appropriations H.R. 3326, Department of 
Defense Appropriations Act, 2010 (the Act). 155 Cong. Rec. H15,042, 
H15,043 (2009). As enacted, the Act provided that the Explanatory 
Statement shall have the same effect as if it were a joint explanatory 
statement of a committee of conference. Public Law No. 111-118 § 1014 
(2009). 

[15] GSA officials told us that the Dun & Bradstreet contract was 
modified to clarify GSA's liability in the event that another agency 
used Dun & Bradstreet data in ways that were not allowed under GSA's 
contract. Specifically, they said that GSA was not responsible for the 
misuse of Dun & Bradstreet's data by non-GSA users. GSA officials said 
other government agencies would have to determine whether their use of 
Dun & Bradstreet's data complied with the terms of the contract. 

[16] When entities register in CCR, they only need to enter their DUNS 
number for their entity name and address information to be imported 
from Dun & Bradstreet's database. GSA officials said that because 
these data come from Dun & Bradstreet, they are subject to the 
limitations specified in the Dun & Bradstreet contract. 

[17] A sources sought notice is a form of market research that is 
designed to allow agencies to describe a specific need and get input 
from industry to determine if there are sources capable of meeting the 
need, whether commercial solutions are available, and whether a 
particular approach is viable. See FAR Part 10. Responses to these 
notices are not offers that could result in a contract. See generally 
FAR 15.201(e). 

[18] The Federal Acquisition Regulatory Council is made up of 
representatives from OMB, GSA, DOD, and the National Aeronautics and 
Space Administration (NASA). The Council is responsible for managing, 
coordinating, controlling, and monitoring the maintenance of, issuance 
of, and changes in the FAR. 

[19] Some of the responding companies offered numbering systems that 
have non-proprietary aspects. For example, one company indicated that 
its identification numbers and data are non-proprietary, but its 
process for generating that information is. Another company told GSA 
that its numbers are not proprietary, but the associated information 
including name, address, and phone number is. 

[End of section] 

GAO’s Mission: 

The Government Accountability Office, the audit, evaluation, and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the 
performance and accountability of the federal government for the 
American people. GAO examines the use of public funds; evaluates 
federal programs and policies; and provides analyses, recommendations, 
and other assistance to help Congress make informed oversight, policy, 
and funding decisions. GAO’s commitment to good government is 
reflected in its core values of accountability, integrity, and 
reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO’s website [hyperlink, http://www.gao.gov]. Each 
weekday afternoon, GAO posts on its website newly released reports, 
testimony, and correspondence. To have GAO e-mail you a list of newly 
posted products, go to [hyperlink, http://www.gao.gov] and select “E-
mail Updates.” 

Order by Phone: 

The price of each GAO publication reflects GAO’s actual cost of 
production and distribution and depends on the number of pages in the 
publication and whether the publication is printed in color or black 
and white. Pricing and ordering information is posted on GAO’s 
website, [hyperlink, http://www.gao.gov/ordering.htm]. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 
TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card, 
MasterCard, Visa, check, or money order. Call for additional 
information. 

Connect with GAO: 

Connect with GAO on facebook, flickr, twitter, and YouTube.
Subscribe to our RSS Feeds or E mail Updates. Listen to our Podcasts.
Visit GAO on the web at [hyperlink, http://www.gao.gov]. 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 
Website: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]; 
E-mail: fraudnet@gao.gov; 
Automated answering system: (800) 424-5454 or (202) 512-7470. 

Congressional Relations: 

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-4400
U.S. Government Accountability Office, 441 G Street NW, Room 7125
Washington, DC 20548. 

Public Affairs: 
Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800
U.S. Government Accountability Office, 441 G Street NW, Room 7149 
Washington, DC 20548.