Dump-DUNS caucus weighs in on the Data Act

The federal government uses the proprietary DUNS identifier to code financial transactions, but with Data Act implementation in full swing, open-data advocates are pushing to go open source.

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Open government activists have a long-standing dislike for the DUNS number, the proprietary business identifier used in government procurement.

The problem as they see it is that because the Dun & Bradstreet's Data Universal Numbering System is proprietary and used by the federal government under license, data can evaporate when the government stops paying, as happened recently when the Recovery Board didn't renew its DUNS license, and payee-level information on award recipients for $800 billion in stimulus spending disappeared.

Back in 2012, a Government Accountability Office report complained that Dun & Bradstreet had locked up the market for unique identifiers, as far as the government was concerned. "This effective monopoly results in part from government regulations and directives that require contractors, grantees, and other entities seeking to do business with the government to obtain a DUNS number," GAO said. The General Services Administration requires the use of a DUNS number in the Federal Acquisition Regulation, and the DUNS number is also prescribed by the Office of Federal Procurement Policy at the Office of Management and Budget.

According to GAO, the U.S. is expected to spend about $18 million on DUNS in fiscal 2015, as part of an eight-year, $154 million contract for DUNS licenses.

Now, some open government activists hope that the implementation of the Digital Accountability and Transparency Act will provide a platform for the government to begin to shift away from DUNS. While it is unlikely that any shift could come through Data Act compliance alone, the expression of a policy preference for an open standard could set the stage for revisions to other federal policies.

The DATA Act sets an ambitious schedule for the federal government to begin publishing spending information as open, machine readable data. As part of the implementation, OMB and the Treasury Department are taking comments from stakeholders on how information from agency ledgers is going to be structured.  In feedback on how recipients of federal funds and awards are to be identified by OMB and Treasury, many commentators are suggesting that the government move away from DUNS to an open, non-proprietary standard, like the Global Legal Entity Identifier.

"Now that the DATA Act has vested authority over recipient identification in Treasury and OMB, the federal government can make an intentional and considered decision for the first time," wrote Hudson Hollister, executive director of the Data Transparency Coalition. He doesn't think Treasury and OMB should drop DUNS immediately, but they "should declare a policy preference for a nonproprietary identifier, take steps toward the reporting of both DUNS and replacement identifiers during a transition period, and set an achievable deadline for the ultimate completion of the switch."

The Association of Government Accountants argued that the proprietary DUNS system is "inconsistent with the open data approach of the DATA Act." The group wrote that "unless DUNS significantly changes its approach to sharing information and modifies its pricing model, we believe the federal government should move to another option."

Hollister told FCW in an interview that his objection was as much philosophical as financial. "Federal data standards shouldn't be subject to licensing at all," he said. Licensing "puts a barrier on the reuse of information and the whole point of open data and the Data Act is that information should just be able to flow."

Brian Williams, who manages federal programs at Dun & Bradstreet, argued for the value of the data behind the DUNS number.

"At the end of the day, the data that D&B provides into the government award management process is operational in nature. We provide high quality, trusted data that conforms to government requirements and process, so that the government can make better decisions and ultimately function better," he said.

Williams also said that he thought it was time to get DUNS requirements out of the Federal Acquisition Regulation and "other places where this standard is codified in hard-to-modify regulatory documents," adding that, "the government should use a system based on its value, not on its inextricability."

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