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Applying for a Grant

Identification numbers needed to apply for federal funds

The requirement for grant applicants, including libraries, to have a DUNS number to receive federal funds is changing. To receive federal funds as a grant recipient, a library must register in the federal System for Award Management (SAM) at SAM.gov and obtain a new, non-proprietary Unique Entity Identifier (UEI) by April of 2022. This applies for any new applications submitted to Washington State Library and for current grantees to continue to receive grant funds from Washington State Library.

Examples of federal funds your library may receive include Library Services and Technology Act (LSTA) grants such as Washington State Library (WSL) Professional Development grant program, the Washington Digital Heritage grant program, the American Rescue Plan Act of 2021 (ARPA) grants, WSL Youth Services Online Tracking Services grants,  direct grants from the Institute of Museum and Library Services (IMLS), etc.

Background

The Office of Management and Budget (OMB) revised the Uniform Guidance for grants (2 C.F.R. part 200) on August 13, 2020. This was the first major updating of the Uniform Guidance since 2014. The relevant requirement that describes the transition away from using DUNS numbers (from Dun & Bradstreet) as entity identifiers to Unique Entity Identifiers (UEI) (from Ernst & Young through SAM.gov) is in 2 CFR § 25.300:

Requirement for recipients to ensure subrecipients have a unique entity identifier.

(a) A recipient [Washington State Library] may not make a subaward to a subrecipient [public, academic, special, and tribal libraries or any other recipient] unless that subrecipient has obtained and provided to the recipient a unique entity identifier [formerly DUNS which is now transitioning to a new UEI number]. 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.

The transition from DUNS to UEI was originally slated for December 2020 but was adjusted to allow additional time for the federal government, grantees, and subrecipients to prepare for the transition.

What does this mean for my library?

For a library to be eligible to apply for and access federal funds after April of 2022, your library (or local government unit or university or tribal authority acting as a fiscal agent) will need to obtain a UEI. If your library’s county/municipality (inclusive of cities, villages, towns, tribal governments and tribal associations, and school districts that operate a library) holds the DUNS number for your library, please contact your municipality/county to ensure they’ve completed the DUNS to UEI transition and get the new UEI number.

1. If your library already has a DUNS number AND is registered in SAM.gov, that DUNS number will be automatically updated to a UEI. This scenario is most likely for libraries using a municipal/county DUNS number and libraries that have received direct federal assistance through a grant from IMLS or another federal agency. Use the SAM Status Tracker to check your organization's registration status with SAM.

2. If your library already has a DUNS number but is NOT registered in SAM.gov, you will need to complete SAM.gov registration to have your DUNS number transitioned to a UEI. This scenario is likely for libraries that hold their own DUNS numbers and have not applied directly to a federal agency for a grant. Use the SAM Status Tracker to check your organization's registration status with SAM. Refer to the “New to SAM.gov for Financial Assistance” PDF from the U.S. General Services Administration for details on how to register for a SAM.gov account and maintain that registration.

3. If your library has neither a DUNS number nor is registered in SAM.gov, you will want to decide whether you will proceed with SAM.gov registration to obtain a Unique Entity Identifier. Washington State Library believes it is important for libraries and/or their local government unit to be able to apply for and receive federal assistance, particularly considering the volume of federal financial assistance that has been provided since March 2020. Having the ability to be flexible and request federal assistance can provide substantial financial assistance in improving library services in your community. Refer to the “New to SAM.gov for Financial Assistance” PDF from the U.S. General Services Administration for details on how to register for a SAM.gov account and maintain that registration.

Between now and April of 2022, libraries may access federal grant funds using either a DUNS number or a UEI. After April of 2022, libraries and systems must have a UEI to apply for and receive federal grant funds. Since current WSL grant applications are for grant funding that may be disbursed after April 2022, all new applications must be submitted with a UEI number.

How long does it take to register with SAM?

(From Grants.gov) Generally, after completing the online registration and sending your notarized letter confirming the entity administrator, it takes up to two weeks to register with SAM, then one business day for updates made in SAM to be reflected in Grants.gov. However, your organization must first have an EIN. If your organization does not have an EIN, you should allow an additional 5 weeks to request and obtain an EIN from the IRS.

Summary

  • DUNS numbers are transitioning to Unique Entity Identifiers (UEI).
  • Libraries will need the new UEI to receive federal funds (e.g., LSTA) after April of 2022.
  • Until April of 2022, libraries can still utilize their DUNS numbers to satisfy the UEI requirement to access federal funds.
  • The UEI can be obtained by registering in SAM.gov for financial assistance.
  • If your library uses a municipal/county DUNS number to access federal funds, contact your municipality/county to ensure you are registered in SAM.gov.
  • If your library uses its own DUNS number to access federal funds or does not have a DUNS number, you should obtain a DUNS number and register in SAM.gov to obtain a UEI.
  • You may need to confirm your entity administrator by sending a notarized letter.

Additional Resources

 

General eligibility

Libraries in Washington State eligible for funding under the LSTA are those libraries included within item 1 or 2 below and that also meet the criteria identified within item 3.

  1. Libraries identified in the legislation, as further defined below.
  2. Libraries operating as not-for-profit entities (i.e., 501c3 status or a similar non-profit designation), or as part of not-for-profit entities.
  3. Those libraries that report to a governing body and have:
    • Written mission statement
    • Fixed location
    • Established and posted hours of service
    • Organized collection accessible to its clientele
    • Designated staff with authority and responsibility for library operations and services
    • Adopted policies consistent with accepted library practices
    • Budget with a defined, ongoing revenue source
    • Legal basis for operation
    • Clearly defined governance structure

Libraries eligible to apply for LSTA funds

Public libraries
Libraries supported wholly or substantially from public funds, available to the general public, and organized under the provisions of RCW 27.12.010.

Academic libraries
Libraries of universities, university colleges, and all other institutions forming part of, or associated with, institutions of higher education (WSCAL, WSLC definition).

Research libraries
"…a library that (i) makes publicly available library services and materials suitable for scholarly research and not otherwise available to the public, and; (ii) is not an integral part of an institution of higher education." (LSTA, Sec 213)

Special libraries or information centers
Libraries maintained by a corporation, an association, a government agency, or libraries which are part of an Indian tribe (as defined in Sec 213 of LSTA), or (any other group) the primary, or only purpose of which is to provide information in support of the objectives of its parent organization. (This definition, as adopted by WSACL and the State Library Commission, will serve as Washington's definition of "Private Library" as identified in the LSTA, Sec 213).

School libraries
Libraries of all public and non-profit elementary and secondary schools that are organized for the use of students, teachers, and parents. Such libraries, or "resource centers," or "instructional media centers," will include books and print and non-print resources, and will have an ongoing funding source and designated staff with responsibility for library operations and services. (WSACL definition)

Library Consortium
"The term 'library consortium'" means any local, statewide, regional, interstate, or international cooperative association of library entities which provides for the systematic and effective coordination of the resources of school, public, academic, and special libraries and information centers, for improved services for the clientele of such library entities." (LSTA, Sec 213) Under this definition, a library consortium in Washington State will be eligible for LSTA funding if such an entity has among its members one or more libraries that meet eligibility requirements as stated above. Furthermore, only those libraries that meet these criteria will be eligible as individual recipients of such funding.

Public libraries currently receiving E-Rate discounts or participating in LSTA funded programs should be aware of this legislation and how it affects the funding of your library. More information can be found on our CIPA page.

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Funded in part by the Institute for Museum and Library Services (IMLS) through the Library Services and Technology Act (LSTA).