No DUNS Numbers, No Subsidy Payments

Regulation | October 06, 2017 | by Colleen Bloom

HUD has clarified that starting with voucher effective dates in December, active DUNS numbers will be required to ensure payments for subsidies.   More tips are provided on this subject, and featured in the article below. 

Clarification was provided in early October that the requirement (discussed below) to have DUNS numbers on subsidy vouchers applies to voucher EFFECTIVE dates of December 1. This means that voucher submissions in November for December payments must include the DUNS number for the owner, or be rejected.

Further, any voucher submissions must include the OWNER DUNS and TIN numbers both or be rejected.  

Provision of PARENT identification is wholly optional. But IF included, must also include both numbers as well. So existing voucher trends of including a Parent TIN must be modified to also include the Parent DUNS number. If one is provided (either TIN or DUNS), both MUST be provided or be rejected

It is strongly recommended that, after submission, checking be done to see if any error codes are generated. An error code 17 will be reflected if the Owner DUNS is not included, and means that the voucher will NOT be paid. Mismatches on Parent numbers will generate error codes 18 – 21, and will also result in non-payment.

 

DUNS Numbers Required for Payments Starting in December

Via a series of regional office emails issued in late May, 2017, HUD announced plans to implement the requirement to include the Dun & Bradstreet’s (DB) Data Numbering System (DUNS) Numbers on all vouchers submitted to Tenant Rental Assistance Certification System (TRACS) starting December 1.

Subsequently, RHIIP Listserv Posting #380 was issued on June 5 reading:

The attached memorandum, dated June 2, 2017, implements the requirement to include the Dun & Bradstreet’s (DB) Data Numbering System (DUNS) Numbers on all vouchers submitted to Tenant Rental Assistance Certification System (TRACS).  Effective December 1, 2017, approximately six months from the date of this memorandum, vouchers that do not contain an active DUNS number will generate a Tenant Rental Assistance Certification System (TRACS) fatal error and will not receive payment until corrected.  
 

Keeping DUNS Numbers Current/Active 

That HUD is now preparing to formally restrict future payment of rental assistance payments to organizations that have and maintain an active DUNS number is not unexpected.   In fact, this enhanced implementation merely expands on a process that first began back in 2004, when HUD first mandated that organizations that apply for HUD grants or other financial assistance must provide a DUNS number with the application.

And, as detailed in HUD Notice H 2011-01, HUD also requires an active DUNS number in order to renew Project-Based Rental Assistance Contracts or Section 202 or 811 Project Rental Assistance Contracts (PRACS) (Note:  The Central Contractor Registry (CCR) referenced in this Notice has been replaced by the System for Awards Management (SAM)s.)
The System for Award Management (SAM), an official website of the U.S. government.  There is NO charge to register or maintain entity registration record/s in SAM.   Details on registering or reactivating registrations in the SAM system are covered in the June 2 HUD memorandum

It is important to note, however, that according to the regional office announcements, “Fatal error corrections in TRACS does not address the status of the entity’s DUNS number or SAMS status.” 
 

Resources

Here are some resources to help you, if you need to check/renew your DUNS numbers now!

  • DUNS numbers can be registered and renewed each year at the following website: https://www.sam.gov/portal/SAM/   
  • A “Quick Start Guide for Updating/Renewing an Entity” that provides guidance for renewing your DUNS number in SAM can be found here

For technical support questions regarding a DUNS number, contact the SAM Federal Service Desk at 1-866-606-8220.  For other questions regarding this memorandum, contact Danielle Garcia at Danielle.D.Garcia@hud.gov.