Recovery Act subrecipient registration

Accessible letter PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2009/TEGL29-08acc.pdf

CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                 ARRA/DUNS/CCR
               ADVISORY SYSTEM                            CORRESPONDENCE SYMBOL
                                                          OFAM/OGCM
          U.S. DEPARTMENT OF LABOR
                                                          DATE
             Washington, D.C. 20210
                                                          June 10, 2009


ADVISORY:          TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 29-08

TO:                STATE WORKFORCE AGENCIES
                   STATE WORKFORCE LIAISONS
                   STATE WORKFORCE ADMINISTRATORS
                   STATE AND LOCAL WORKFORCE INVESTMENT BOARDS

FROM:              DOUGLAS F. SMALL /s/
                   Deputy Assistant Secretary

SUBJECT:           Dun & Bradstreet (D&B) Data Universal Numbering System (DUNS)
                   Number/Central Contractor Registration (CCR) Mandatory Requirement for
                   Federal Grant Sub-recipients under the American Recovery and Reinvestment
                   Act of 2009

1. Purpose. To inform the workforce system of the mandatory requirement for sub-recipients,
i.e., any first-tier subcontract or sub-award funded in whole or in part under the American
Recovery and Reinvestment Act of 2009 (Recovery Act), to obtain a DUNS number
www.dnb.com. Any such sub-recipient must also establish and maintain active and current
profiles in the CCR at www.ccr.gov.

2. References.
   ▪ The American Recovery and Reinvestment Act of 2009, Public Law 111-5
   ▪ The Office of Management and Budget (OMB) Implementing and Updated
      Guidance for the American Recovery and Reinvestment Act of 2009, dated
      February 18 (OMB# M-09-10) and April 3, 2009 (OMB# M-09-15)
   ▪ Federal Register Notice, Vol. 74, No. 61, Wednesday, April 1, 2009
   ▪ Training and Employment Guidance Letter No.17-08

3. Background. Pursuant to the Recovery Act, Division A, Section 1512(h), recipients of
Recovery Act funds must be registered in the CCR database at www.ccr.gov. To register in the
CCR database, the Federal Acquisition Regulation requires that an entity have a valid DUNS
number. Because recipients must report information on their first-tier contracts and awards, the
OMB guidance referenced in Section 2 also requires that sub-recipients register their DUNS
number in CCR as a way to help ensure consistent reporting of data about each entity, thereby
making the data more useful to the public. Without this requirement, multiple recipients doing
business with the same entity may use different variations of the entity’s name, address, or
parent organization when they each report on their awards to the entity.



 RESCISSIONS                                              EXPIRATION DATE
 None                                                     Continuing

OMB has determined that there is a need for improved statistical tracking of Federal grants,
cooperative agreements, and loans, posed by the Recovery Act’s transparency and accountability
framework. Use of a DUNS number will provide a means to identify entities receiving Federal
awards. The DUNS number will be used for tracking purposes and to validate address and point
of contact information. The DUNS number is already used by the Federal government to
identify entities receiving Federal contracts and grants.

4. Applicability. The DUNS/CCR requirement applies to all types of entities including direct
recipients applying for Federal grants, cooperative agreements, or loans under the Recovery Act
programs or activities and sub-recipients receiving funds under such awards. Under this
requirement, a sub-recipient is defined as a non-Federal entity that expends Federal awards
received from a pass-through entity to carry out a Federal program or activity, but does not
include an individual that is a beneficiary of such a program. A sub-recipient may also be a
recipient of other Federal awards directly from a Federal awarding agency. Recipients and sub-
recipients must also maintain current registrations in CCR at all times during which they have
active Federal awards funded with Recovery Act funds.

5. Action Requested. There are two new requirements for entities that anticipate being a sub-
recipient of Recovery Act funds for Federal grants, cooperative agreements, or loans: 1)
obtaining a DUNS number, and 2) registering with the CCR.

   a. Obtaining a DUNS number. The first requirement is that sub-recipients must obtain a
   DUNS number in advance of a specific award. A DUNS number is a unique nine-character
   identification number provided by the commercial company D&B. Each sub-recipient is
   responsible for obtaining the number. Prior to requesting a DUNS number, the organization
   should investigate if a DUNS number has already been issued to the organization. Most
   large organizations, independent libraries, colleges and research universities already have
   DUNS numbers. Sub-recipients can obtain a DUNS number by calling a toll-free number
   800-234-3867. The approximate time it takes to get a DUNS number is 10 to 15 minutes,
   and there is no charge. Applicants may also obtain a DUNS number by accessing the D&B
   Web site at http://fedgov.dnb.com/webform. The approximate time to create the number
   online is one business day. Applicants must note that information entered and used to obtain
   the DUNS number will be used to pre-populate the CCR.

   After obtaining a DUNS number, sub-recipients should wait 24 to 48 hours to register with
   the CCR so that its DUNS number has time to become activated in the D&B records
   database. Once the DUNS number is established, the direct grant recipient and sub-recipient
   must maintain current registrations in the CCR at all times in which they have active Federal
   awards funded with Recovery Act funds.

   b. Registering with the CCR. The second requirement for sub-recipients under the Recovery
   Act is to register with the CCR. The CCR is a government-wide registry for vendors doing
   business with the Federal government. The CCR centralizes information about grant
   recipients and also provides a central location for grant recipients to change organizational
   information. Information for registering with the CCR and online documents can be found at
   www.ccr.gov. Grant and sub-grant recipients should review the Central Contractor
   Registration user guide at http://www.ccr.gov/handbook.asp. If an organization has the
   necessary information ready, online registration will take approximately 30 minutes to
   complete; however, depending upon the size and complexity of the organization it could take

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   much longer. The CCR registration process also includes a validation on the Internal
   Revenue Service (IRS) Employer/Taxpayer Identification Number (EIN/TIN) of each new
   and updating CCR registrant according to the IRS records. Sub-recipients (and direct grant
   recipients) must annually update or renew their registration at www.ccr.gov, by clicking on
   the link entitled, “Update or Renew Registration.” If you need assistance with the CCR
   registration process, you may contact the CCR Assistance Center, 24 hours a day, 7 days a
   week at 888-277-2423 or 269-961-5757.

       1. CCR Use of D&B Information. In July 2006, CCR implemented a policy change
          related to data elements. Under this policy change, instead of obtaining name and
          address information directly from the registrant, CCR obtains the following data
          fields from D&B: Legal Business Name; Doing Business as Name; Physical
          Address; and Postal Code (Zip+4).

           Registrants will not be able to enter or modify these fields in CCR as they will be pre-
           populated using previously registered DUNS records data. During a new registration,
           or when updating a record, the registrant has a choice to accept or reject the
           information provided from the D&B records. If the registrant agrees with the D&B
           supplied information, the D&B data will be accepted into the CCR registrant record.
           If the registrant disagrees with the D&B supplied data, the registrant must go to the
           D&B Web site at http://fedgov.dnb.com/webform to modify the information
           contained in the D&B records before proceeding with its CCR registration. Once
           D&B confirms the updated information, the registrant must revisit the CCR Web site
           and “accept” the D&B changes. Only at this point will the D&B data be accepted
           into the CCR record. This process can take up to 2 business days for D&B to send
           modified data to CCR, and that timeframe may be longer if the data is sent from
           abroad. Once a registration is submitted successfully, the organization will receive an
           email welcoming it to CCR.

       2. CCR EIN/TIN Validation. To complete the CCR registration and satisfy the
          Recovery Act requirement as a sub-recipient for the Department of Labor (DOL)
          grants, the EIN/TIN combination you provide to the IRS Consent Form must match
          exactly to the EIN/TIN used in Federal tax matters. It will take approximately up to 2
          business days to validate new and updated records prior to becoming active in CCR.
          Please be sure that the data items provided to D&B match information provided to the
          IRS. If the registration in D&B and the CCR do not match the IRS information, an
          error message will result. If there are discrepancies, they must be resolved before the
          registration will be completed. DOL recommends that applicant organizations
          carefully review their D&B and CCR registration information for accuracy
          immediately upon publication of this notice. If you have questions about your
          EIN/TIN, call 800-829-4933.

6. Inquires. Questions regarding this issuance should be directed to the appropriate
Employment and Training Administration regional office.




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