8-SAM.gov UEI QA 508.pdf
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- Solicitation number
- RFP-211-25
- Issued by
- Boulder County, Colorado
About this file
This document is a Financial Policy Q&A from the Office of the Chief Financial Officer focused on the System for Award Management (SAM.gov) and Unique Entity Identifier (UEI) guidance for entities doing business with the U.S. Federal government, particularly the Federal Highway Administration (FHWA). The document provides comprehensive information about SAM.gov registration requirements, explaining that entities including for-profit organizations, nonprofits, government contractors, state/local governments, tribal governments, and higher education institutions must register to apply for federal financial assistance or conduct business with the federal government.
Key details include the replacement of DUNS numbers with UEIs as of April 4, 2022, and the requirement that all entities doing federal business must have their own UEI unless specifically exempted. The document outlines the distinction between "signing up" for a SAM.gov account (which allows access to features like saving searches) and fully registering, which authorizes direct business with the government. Additional guidance covers how State DOTs can add UEIs to the Fiscal Management Information System (FMIS), update recipient information, and manage banking details, with an emphasis on maintaining accurate information for Digital Accountability and Transparency Act reporting purposes.
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System for Award Management (SAM.gov) & Unique Entity Identifier (UEI) Q&A
Last Updated: 4/1/2025
I. Overview
The System for Award Management (SAM.gov) is an online, comprehensive application that must be used by entities that do business with the U.S. government. SAM.gov uses the term “entity” to refer to prime contractors, organizations or individuals applying for assistance awards, those receiving loans, sole proprietors, corporations, partnerships, and any U.S. Federal government agencies desiring to do business with the government. Determinations regarding whether a SAM.gov registration or a unique entity identifier (UEI) is required are based on whether the entity is determined to be a recipient, a subrecipient, a subrecipient of a subrecipient (second-tier subrecipient), or a contractor under Federal awards. To do business with the FHWA, entities must comply with Title 2, Code of Federal Regulations (CFR) 25.300 unless exempted by 2 CFR 25.110. Consult with the FHWA Agreement Officer (AO) or FHWA Division Office POC for clarifications.
II. Q&A
Q1: What is SAM.gov?
SAM.gov is the official government-operated website used to register for and obtain a UEI and do business with the Federal government, search for contract opportunities, find wage determinations, and more. The site is used to:
Register to do business with the U.S. Government;
Update, renew, or check the status of an entity’s registration;
Get a UEI;
Search for entity registration and exclusion records;
Search for assistance listings (formerly CFDA.gov), wage determinations (formerly
WDOL.gov), contract opportunities (formerly FBO.gov), and contract data reports (formerly part of FPDS.gov);
View and submit BioPreferred and Service Contract Reports; and Access publicly available award data via data extracts and system accounts
Q2: Is a DUNS Number still required for entities doing business with the Federal government?
No. Beginning April 4, 2022, the UEI from SAM.gov is the official identifier for those doing business with the Federal government. The DUNS number is no longer valid for Federal award identification.
Non-Federal entities that had a DUNS number were automatically assigned a UEI.
Q3. What does it mean to “register” for a UEI in SAM.gov?
“Registering” is required for an entity to do business directly with the government through SAM.gov.
An entity must register and provide necessary information to be able to bid on contracts and other procurements, or apply for Federal financial assistance (e.g., grants, loans). The process for entity registrations includes getting the UEI and requires assertions, representations and certifications, and other information about the business.
Financial Policy Q&A Office of the Chief Financial Officer 1
Q4: Who must register in SAM.gov?
A SAM.gov registration is required for any entity that applies for Federal financial assistance and all recipients of Federal financial assistance other than those exempted by statute or exempted under 2 CFR
25.110. Entities required to register in SAM.gov include for-profit organizations, nonprofit organizations, government contractors, government subcontractors, State governments, local municipalities, tribal governments, and institutions of higher education. Contractors doing work only under State contracts (such as for State DOTs), even if they are reimbursed with Federal funds, are not required to register in SAM.gov.
Q5. What does it mean to “sign up” (versus register) for a SAM.gov account?
“Signing up” means establishing an account and SAM.gov profile. User account credentials are managed by login.gov, which allows an entity to access many Federal government websites with one set of credentials. An entity must sign up to use features of SAM.gov such as saving searches and viewing standard reports. The “sign up” process does not authorize an entity to do business directly with the government through SAM.gov.
Q6: Who is required to have their own UEI?
All entities that do business with the Federal government must have their own UEI unless exempted by 2 CFR 25.110. In accordance with 2 CFR 25.300, a subrecipient of a Federal award must have its own UEI. However, subrecipients or subcontractors can obtain a UEI for their organization without completing a full entity registration in SAM.gov. SAM.gov requires minimal information to get a UEI without registration. Under 2 CFR 25.105, subrecipients of subrecipients (second-tier subrecipients) and contractors under Federal awards are not required to obtain a UEI or obtain a SAM.gov registration.
Recipients may not share a UEI.
Q7: Do State DOT’s need to apply for a UEI if they are already registered in SAM.gov?
No. If the State DOT is already registered in SAM.gov (active or not), it already has a UEI which is viewable at SAM.gov.
Q8: How can a State DOT get a UEI added to FHWA’s Fiscal Management Information System
(FMIS)?
State DOTs should work with their designated FHWA Division Office to request the addition of a specific UEI into FMIS by providing the name and UEI of the entity. The State DOT is asked to identify when they are acting as a passthrough for a subrecipient. Subrecipient Names/UEI's are submitted with a project authorization to document the party responsible for disbursement of Federal funds. Since the SAM.gov database is a centralized repository for entities doing business with the Federal government, and to streamline the list of potential subrecipients in the drop-down fields, the FHWA FMIS does not include all UEI's available.
Q9. How can a recipient update/correct a UEI in Delphi?
Grant transactions in FHWA financial systems are captured in USAspending.gov for the Digital Accountability and Transparency Act reporting purposes. Any changes in the UEI and/or recipient name during grant performance will create a discrepancy between FHWA financial systems and USA Spending. Please contact the FHWA AO and/or Agreement Specialist (AS) to ensure they are made aware of these instances. The assigned FHWA AO/AS can further advise on a resolution.
Q10. If a recipient wants to update their banking information to deposit Delphi/iSupplier payments, do they need to submit a request to their FHWA AO or AS?
Office of the Chief Financial Officer 2
No. Banking information is linked to the UEI and contained in SAM.gov. The recipient can update banking information in their SAM.gov account.
Office of the Chief Financial Officer 3
| I.Overview |
| II.Q&A |
| Q1: What is SAM.gov? |
| Q2: Is a DUNS Number still required for entities doing business with the Federal government? |
| Q3. What does it mean to “register” for a UEI in SAM.gov? |
| Q4: Who must register in SAM.gov? |
| Q5. What does it mean to “sign up” (versus register) for a SAM.gov account? |
| Q6: Who is required to have their own UEI? |
| Q7: Do State DOT’s need to apply for a UEI if they are already registered in SAM.gov? |
| Q8: How can a State DOT get a UEI added to FHWA’s Fiscal Management Information System (FMIS)? |
| Q9. How can a recipient update/correct a UEI in Delphi? |
| Q10. If a recipient wants to update their banking information to deposit Delphi/iSupplier payments, do they need to submit a request to their FHWA AO or AS? |
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