Issue: Currently, NIH employs the IPF number to uniquely identify grantee organizations that have received awards through extramural funding agreements. This number, consisting of 7 numeric digits, has provided a more than adequate degree of source of identifiers since its inception in the 1960's.

Within the last several years, however, the number of available IPF combinations is becoming limiting. This limitation coupled with the fact that the NIH grantee organization population continues to grow has resulted in recent proposal to increase the IPF number to 8 digits. Independent of these NIH considerations, other trans-government electronic grants administration initiatives are now being promoted requiring the use of universal identifiers for grantee/contractor organizations who transact grantee business with multiple federal agencies.

Recommendation: These facts strongly suggest a successor to the IPF number. The Dun and Bradstreet Universal Numbering System (DUNS) number represents the best available successor. It meets the requirements for a successor for several reasons:

• DUNS numbers are of a fixed length and format (9 digits) that has been well-documented and publicized to the private, commercial and academic business/organizational community. Dun and Bradstreet claims that such DUNS numbers have now been created and can be used to track more than 62 million companies worldwide. Dun and Bradstreet further indicate that the world's most influential standards-setting organizations, more than 50 global, industry and trade associations, and the US Federal Government recognize, recommend and/or require the DUNS number in order to form the basis for electronic commerce and business performance monitoring.
  
  
• The DUNS numbering system can also accommodate organizations with complex organizational hierarchies. Each organization with subsidiary components can have unique DUNS numbers for each subcomponent. Dun and Bradstreet provides links for the DUNS numbers for parents, subsidiaries, headquarters and branches.
  
  
• DUNS numbers can be obtained on-line via the Web, and obtaining the number, and later updating information is complete free. The procedure is very straightforward, including the creation of a business profile. Once the form is completed and submitted to Dun and Bradstreet, the information is verified by Dun and Bradstreet staff through e-mail notification and follow-up telephone interview. Unless the information is personally verified via a telephone call, the DUNS number is not assigned. A similar verification process is in place to oversee requested changes in the business profile.
  
  
• DUNS numbers can be easily verified on-line via the Web. Any member of the public can query the DUNS database for a description of the business profile of any organization with a DUNS number. The database can be queried with the DUNS number or the name of the organization. This feature will facilitate any need to verify grantee organizations citing a DUNS number.

IPF to DUNS Transition: Currently, when a competitive application is submitted the Entity Identification Number (EIN) is the identifier supplied as part of the application that determines the identity of a grantee organization, provided for as item #12 on the Form 398 face page. When the application is received in CSR Receipt and Referral, the EIN on the application is compared to acceptable EIN numbers for that grantee organization. The internal comparator to the EIN(s) is the IPF number (one IPF may have many EINs). A correct match results in normal processing of the application, while any lack of correspondence with the accepted numbers results in the need for staff to verify the EIN (that relates to a specific IPF number). Unfortunately, there exists a considerable number of applications where the EIN does not correspond (some estimates of > 10% of applications received). In order for complete processing of these applications through award, the EIN (IPF) must be verified by NIH staff, often times via telephone call to the grantee organization.

A proposal was put forward in 1999 whereby an IPF number was to be included on the face page of the Form 398 application (within the applicant organization item) as a means of verification of the organization distinct from the EIN number. The use of IPF for this purpose was to have been limited to organizations registered to use the NIH Commons, since all other organizations would not be aware of the identity of their IPF number. For organizations who included their IPF number on the applications, Receipt and Referral staff would know to overlook any lack of reconciliation of the EIN number.

This potential solution was complicated by the fact that IPF number was (and still is) not required to submit a paper application, nor is there any place on the face page of Form 398 to accommodate it. The first attempt to request inclusion of the IPF number, even among organizations that had registered for the Commons generated confusion and distress. At best, this solution was implemented to serve as an interim strategy until an alternative long-term solution could be put in place.

The alternative solution that would appear more acceptable is to immediately implement use of the DUNS number on paper applications. The DUNS number is not currently required, though the Form 398 (revised 4/98) does provide a field for submission of DUNS (face page item #12). Accordingly, if the DUNS number became a grantee organization unique identifier, the mechanism for its capture on the Form 398 is OMB approved and available.

The specific proposal would be for the DUNS number to be the primary institution identification number. Until such time that all grantee institutions were using DUNS as an identifier, the current EIN number comparison would be required. For cases where DUNS was provided the Receipt and Referral data entry would have to accommodate the DUNS entry. Once entered, the DUNS could be compared through a lookup table in the database system to the EIN or IPF number. To prepare for the use of DUNS on the Commons, during a transitional phase users would be given the option of either entering the IPF number (which they were given commensurate with Commons registration), or DUNS. The linking of a DUNS number with a specific grantee organization would be made part of the NIH Commons registration process. Once the DUNS was formally acknowledged it would be stored in IMPAC II as part of the grantee organization profile. IMPAC II has been designed to carry this data element. A similar process could allow for the designation of multiple DUNS numbers per grantee organization, similar to the use of multiple EINs per grantee organization (i.e. IPF).

With the DUNS formally recognized and stored in IMPAC II, when a Form 398 is received in CSR Receipt and Referral the DUNS number included on the Form 398 could be compared to the DUNS number that was stored in IMPAC II. A correct match would result in normal processing of the application, while any lack of correspondence would result in the need for staff to verify the DUNS, or alternatively revert back to the EIN for identity verification.

Grantee Organization Requirements for Use of DUNS number as Unique Identifier: The provision for use of DUNS number by the grantee organization would require that a one or more DUNS numbers be provided by the grantee organization to establish how the NIH would recognize that specific organization. This would require that the DUNS number (or numbers in the case of large organizations) be part of the Organizational Profile. The data dictionary for the Organizational Profile already allows for the capture and storage of DUNS numbers. This possibility is significant in that it allows the grantee organization to identify and update, as needed, the DUNS numbers necessary to transact business and make awards to the specific grantee organization. It would encourage grantee organizations to maintain the list, in light of the fact that if the list is inaccurate it could have dire consequences upon receipt of an award. At the same time, once the original DUNS number/IPF number verification was made, further changes made by the grantee organizations should not require additional verification by NIH staff.

In practical terms, DUNS number is currently part of the Organizational Profile. However, the current implementation only allows for a single DUNS number. Scripts that support this function would be changed such that the grantee organization Signing Official who has authority to alter the Organizational Profile could identify multiple DUNS numbers. Addition of each new number would require a brief description of the grantee organization subsidiary, consistent with the Dun & Bradstreet registration information, to allow for confirmation of identity by NIH Staff if necessary.

Implementation of DUNS into the NIH Commons: Relatively minor changes in the Commons interfaces would allow for the use of DUNS number. Currently, the grantee organization user must insert the IPF number as one of the unique identifiers pursuant to logging onto the NIH Commons. Commensurate with introduction of DUNS as a unique identifier on the Form 398, the Commons logon screen would be modified for the user to provide either the DUNS number for the grantee organization or the IPF. The fact that the format for the two different numbers is distinct suggests that the interface could automatically recognize which number type had been entered, and accordingly perform the appropriate lookup within the Commons registration/authorized users database.

Proposed Timeline for Implementation of DUNS: There are currently ~170 organizations registered to use the NIH Commons. Technically, the first step in implementing DUNS would be to make changes to the Commons interface scripts to allow for the Organizational Profiles of the registered organizations to add the DUNS numbers. Once available, the registered organizations could submit DUNS numbers, while at the same time, any new organizations that began the registration process would be required to provide DUNS number and description for each subsidiary organizational component.

Once DUNS numbers and descriptions were available in the Commons database, numbers could be verified for all organizations already registered for the Commons. Following verification of Commons registered organizations, a similar process would become part of the ongoing Commons registration process. Any new resources that would be necessary on behalf of IMPAC II staff in order to verify DUNS could be identified and provided by contract support.