Hi all,
For anyone who is out there feeling the anxiety of this that propelled me through my whole day Friday, I’d like to summarize what is putting my mind at ease:
1. The April 2022 date that Debbie, Catherine, and others have shared.
2. The UEI is transitioning from Dun & Bradstreet (DUNS (which actually stands for Data Universal Numbering System or something)) holding the contract to provide that entity verification to Ernst & Young<https://www.gsa.gov/about-us/organization/federal-acquisition-service/office-of-systems-management/integrated-award-environment-iae/iae-information-kit/unique-entity-identifier-update>. (How do I get that gig?)
* DUNS = Bye, bye
* UEI from E&Y = Hi, hi
3. Dennis told me that he had heard from a number of his states, so I am sure that Madison and Michelle are also sifting through several contacts from us saying, “What the hey?” Dennis assured me that these questions will be discussed and address at the Day 1: Tuesday, March 30, 2021 2:40 – 3:25 pm (Eastern) 2 C.F.R. part 200 Updates session with Cam Trowbridge, IMLS, will cover all the questions and concerns that we’re raising.
4. # 10 on the Top Ten that Rachel just re-shared is one of our accountant’s responsibilities, so I can breathe easy on that one. Sorry for that of you who do FFATA reporting. (Or is it pronounced FFATA? Let’s call the whole thing off!)
For those of you asking for follow-up about what I asked specifically IMLS to address, here that is:
1. I informed Dennis that it is highly unlikely that our libraries have existing SAM.gov registrations that can be given an automatic UEI. From a broader agency standpoint (we’re housed within the Department of Ed (Department of Public Instruction (DPI))), I believe this is also the case for school districts since they access federal funds via DPI (food service comes from USDA and passes through DPI, the US Department of Education passes ESEA and IDEA (plus many other grants) through DPI. School districts infrequently receive funds directly from the federal government (like Title V, Part B, Subpart 1 of ESEA for rural schools through the Small, Rural School Achievement Program (SRSA)). Only SLAAs and entities that access funds directly from federal sources like tribal libraries and those ambitious libraries that apply for IMLS discretionary grants are already signed up. The ones that are not likely do not have dedicated grants staff.
* So I feel this is going to be a big lift, not from the sense that doing this “partial signup” with SAM.gov is actually hard, but the messaging and hand-holding with our libraries is going to be very difficult and time consuming.
* I worry that libraries probably don’t see the usefulness of having a DUNS number now and selling them on the usefulness of this same UEI may also prove difficult. I worry that our “participation rate” for having these identifiers will drop.
i. We can use the NEH and IMLS discretionary grants as carrots to complete SAM.gov signups. (“Look at all the grant opportunities that will be available to you if you just complete this and the grants.gov signups!”)
* I am also concerned with libraries having to work with municipalities (potentially) to complete this sign-up. It’s not something that school districts would have as much of an issue with since school districts have infrastructure and dedicated staff that can manage this. Libraries likely do not have dedicated staff for this purpose (at least in Wisconsin).
1. With April 2022 as the deadline to switch, this falls right near the end of the (state) FY2022 grant year for schools or for libraries and regional library systems. I asked if there would be some sort of grandfathering in of those split-year grants. Depending on how that works with the split – if one check at the start for a DUNS is sufficient in 2021 and then start checking again on new grants in 2022 – July 1, 2022 might be more the practical deadline in WI. Libraries would need to prepare for FFY2022 LSTA money and not necessarily for ARPA or FFY2021 LSTA if that is the case.
2. Our obligation under 2 CFR § 25.300 (b)<https://ecfr.io/Title-2/Section-25.300> should be satisfied by announcing in a grant announcement that this is a prerequisite for getting a grant. In reality, that 4+ week timeline doesn’t really lend itself to announcing in a grant announcement. After getting more information from IMLS, I will likely be launching an initiative to get libraries signed up well in advance of our next round of granting. See the NEH/IMLS discretionary “carrot” above in 1bi.
3. IMLS will be trying to retrieve more information from SAM.gov to show the workflow for getting signed up – like a PDF step-by-step guide. IMLS will share that information if successful.
4. How does this impact our ability for subrecipients to pass money through from regional entities to their member libraries? In Wisconsin, would a member of a regional library system have to have a UEI to receive money that is passed through one of our subrecipients?
5. Is there some way to get a list of who is already signed up so we can do targeted messaging?
6. Is there an opportunity for DUNS numbers to be rolled over to the new UEI system brought to us by Ernst & Young? (a shot in the dark – here’s hoping)
7. This also appears like it’ll have bigger implications within WISEgrants (our federal grants management software) and the things that the current unique identifier DUNS numbers feeds into. Those updates are probably as easy as renaming their DUNS table (knock on wood), but probably more involved as are so many things in programming. My understanding is that the WISEgrants team will be looking into this closer along with School Financial Services.
So this is fun! If you feel like I missed something that IMLS can help with, feel free to send that directly to your program officer so that we can all get the most detailed, consistent messaging from our program officers. They’re appreciative of knowing how this impacts us and want to help in any way they can.
Have a good week!
Michael Dennison
Public Library Consultant – Library Data, Funding, and Compliance
Wisconsin Department of Public Instruction
Division for Libraries and Technology
(608) 266-5196
michael.dennison at dpi.wi.gov<mailto:michael.dennison at dpi.wi.gov>
From: lstac <lstac-bounces at omls.oregon.gov> On Behalf Of Katie McDonough via lstac
Sent: Monday, March 22, 2021 10:13 AM
To: lstac at omls.oregon.gov
Subject: [lstac] Fw: Sam.gov and subrecipients
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
I was on grants.gov yesterday, and it said to use our DUNS as the Unique Entity Identifier.
Katie McDonough
Administrative Librarian
Delaware Division of Libraries
121 Martin Luther King Jr. Blvd. North
Dover, DE 19901
302-257-3012
________________________________
From: lstac <lstac-bounces at omls.oregon.gov<mailto:lstac-bounces at omls.oregon.gov>> on behalf of Debbie Hall via lstac <lstac at omls.oregon.gov<mailto:lstac at omls.oregon.gov>>
Sent: Monday, March 22, 2021 10:07 AM
To: lstac at listsmart.osl.state.or.us<mailto:lstac at listsmart.osl.state.or.us>
Subject: [lstac] Sam.gov and subrecipients
The following is from the tips Teri sent earlier this month. This is going to take a lot of discussion. I wish our conference was in person this year.
I need to check if there is a short SAM.gov registration option, as it says below a complete registration is not required.
Would a DUNS number or TIN work as a Unique Entity Identifier?
9. Unique Entity Identifier (UEI) and System for Award Management (SAM):
o Recipient requirements of subrecipients.
The following is new: 2 C.F.R. § 25.300 Requirement for recipients to ensure subrecipients have a unique entity identifier. (
a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier.
(b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section.
Debbie
Deborah N. Hall
Manager of Grants & Special Projects
Arkansas State Library
A Division if Arkansas Department of Education
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