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    Does an intermediate home office require a DUNS if it does not issue proposals or receive awards but allocates costs to business segments which includes CAS covered contracts?


    According to Dunn and Bradstreet (D&B), if the business entity is a United States Government contractor, vendor or grant recipient, it is required to have a Data Universal Numbering System (DUNS) number when doing business with the Government. The Federal Register specifically outlines policy for applicants applying for Federal grants or cooperate agreements to provide a DUNS number. The policy states that every application for a new award or renewal of an award, including applications or plans under mandatory grant programs, submitted on or after October 1, 2003 must include a DUNS number for the applicant. Unless an exemption is granted, an application will not be considered complete until a valid DUNS number is provided by the applicant. Agencies are not authorized to grant exceptions from the policy. Requests for exemptions must be directed to the Office of Management and Budget (OMB). For Federal purposes, the applicant is not required to submit DUNS numbers for entities with which it may enter into subawards; only the primary applicant.

    We  highly recommend that you consult with your legal office for assistance in determining if the aforementioned company is the business entity or a subaward.

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