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Having Trouble with the Transition from CCR to SAM?

by Published On: Mar 02, 2012Updated On: Feb 25, 2013
HUD

All rental assistance subsidy payment programs are subject to ongoing requirements for annual online systems registration and certification, with the Dun and Bradstreet Number System (DUNS) numbers as the starting point. But, the registry used to record such certifications changed in 2012, and problems experienced by some are triggering "offers" for a fee-based resolution which are inappropriate.   

If you have problems accessing your information, which by now should be fully migrated to System for Award Management (SAM) and the SAM helpdesk is not responding, Christopher Davies is the point of contact in the HUD controllers office who is taking lead on SAM migration.   

Please send an email to christopher.b.davies@hud.gov (copy cbloom@leadingage.org and kerry.e.hickman@hud.gov) detailing your issues/concerns and attempts to resolve the issue so far.

System of Award Management Background

In mid 2012, the centralized registration system known as CCR was replaced by a new system which goes by the System for Award Management (SAM), which went live July 29, 2012. 

While the transition of data from CCR to SAM is meant to be seamless, there are a few key points for users registering DUNS in SAM to remember:

  • SAM is completely free, both to register and to use.
  • Registration renewal prompts from the new system should not be ignored.
  • An inactive DUNS number could cause potential problems for payments on grants or contracts received
  • CCR no longer exists; SAM has replaced CCR.

Unfortunately, the transition has not been wholly seamless. While most report having no difficulty, some have had problems. 

If you had an account in CCR, all your information is now in SAM -- but your CCR login info will not work in SAM. Unless you opted out of the public search, you should be able to see your record by logging into SAM and doing a public search on your DUNS.

Unless a change in your business circumstances requires a change in order for you to be paid, or to be awarded a contract or a grant, you should not have to update your records right away (check your expiration date). 

If you need to update/renew/change your record:

  1. Start at SAM.gov.
  2. Click on Create an Account.
  3. Follow the prompts to create an individual account and migrate your records/roles from CCR. The migration roles document will tell you how to do so.
  4. Log in.
  5. Click on Register/Update Entity.
  6. Find your record in the Complete Registrations section and begin your update. 

The updating or renewing document provides instructions. These documents are on the Help tab of sam.gov.

If you have problems, please submit a ticket via the SAM help desk: the Federal Service Desk. It is recommended you do so online, rather than wait on the phone on hold. If you don't have an account with FSD already, you'll need to create one on the “Your Account” page in order to submit a ticket.

DUNS Background 

On April 26, the U.S. Department of Housing and Urban Development (HUD) published Notice H 2012-16: "Notice Requiring Owners with Project-Based Section 8 Rental Assistance Contracts or Section 202 or 811 Project Rental Assistance Contracts or Rental Assistance Payments or Rent Supplement Contracts to Obtain Dun and Bradstreet Number System (DUNS) Numbers and to Register in the Central Contractor Registration (CCR)." 

By now, all Section 202 PRAC, Rent Supplement and RAP subsidy properties should have joined with other Section 8 subsidy recipients in obtaining a DUNS number, and certifying to and maintaining a valid registration in the CCR database and/or the SAM database (for new sites, opened since April 29, 2012). 

From this point forward, all rental assistance subsidy payment programs are subject to ongoing requirements for annual renewal of the SAM certification, or risk having their DUNS numbers become  inactive.  An inactive DUNS number could cause potential problems for payments on grants or contracts received. 

As expected and previously reported on, this notice formally extends the requirement to obtain, submit and maintain valid DUNS and SAM registrations to the Section 202 PRAC program, as well as all other rental subsidy programs. 

There is no requirement to re-submit the certification, unless directed to do so by your local HUD office. 

What's in Notice H 2012-16?   

Rental assistance payments made under the following will be covered by this reporting requirement: 

  • Project-Based Section 8 Housing Assistance Payments (HAP) Contracts. 
  • Section 202 or 811 Project Rental Assistance Contracts.
  • Section 236 Projects with Rental Assistance Payments Contracts. 
  • Section 221(d)(3) Below Market Interest Rate, Section 231, Section 236 (insured and non-insured) Projects, and Section 202 Projects with Rent Supplement Contracts. 

The law affects both the legal entity that receives the funds (typically the partnership, association or corporation listed as Project Owner in contract documents) as well as the parent company, if the recipient is owned or controlled by another entity.
 
Covered entities must obtain a DUNS number and have an active, valid registration in CCR within 60 days of the publication date of this notice (June 26, 2012) and must submit the attached certification to their local HUD office to demonstrate compliance with the requirements of this Notice. 

There is no requirement to re-submit the certification, unless directed to do so by your local HUD office.  

At the end of the 60 day period, HUD will run the listing of DUNS numbers received in response to this notice, against the extract it receives from CCR to ensure compliance. 

An owner’s failure to obtain a DUNS number and CCR registration within this timeframe may result in the Department’s suspension of housing assistance payments or rental assistance payments. 

This Notice also requires owners to maintain their CCR registration in order to continue to receive housing assistance or rental assistance payments.
 
HUD expects to modify the reporting format for TRACS to capture the owner’s DUNS number, though this is currently not possible.
 
The full notice contains the technical aspects of how to obtain/report these DUNS numbers, if not done previously, can be found in the full notice.

Yearly Renewal Requirements; Renewing an Expired Registration 

Data for all rental assistance subsidy payment programs that were entered into the Central Contractor Registry (CCR) for certification has been transferred to the System for Award Management (SAM) as of July 29, 2012.

As with CCR, owner/agents are required to maintain their SAM certification by renewing and revalidating their registration at least once every 12 months from the date previously registered. 

SAM will send out a series of emails urging timely renewal, if you did not get them or respond to them, you do not have to start the registration process over again. Theresa Fields at HUD headquarters provided us with the following information:

Unless a change in your business circumstances requires a change in order for you to be paid, or to be awarded a contract or a grant, you should not have to update your records right away (check your expiration date). If you need to update/renew/change your record, start at http://sam.gov , click on Create an Account, and follow the prompts to create an individual account and migrate your records/roles from CCR. The migration roles document will tell you how to do so. 

Then, log in, click on Register/Update Entity, find your record in the Complete Registrations section and begin your update. The updating or renewing document provides instructions. These documents are on the Help tab of sam.gov.

If you have problems, please submit a ticket via the SAM help desk: the Federal Service Desk (FSD). It is recommended you do so online, rather than wait on the phone on hold. If you don't have an account with FSD already, you'll need to create one on the “Your Account” page in order to submit a ticket.

When a SAM registration has expired, the DUNS number becomes inactive.  An inactive DUNS number could cause potential problems for payments on grants or contracts received. 

There is no charge for registering for or re-activating a registry in SAM.

More Historical Background: Synopsis of Prior Articles

A HUD field office missive cautions multifamily housing providers about the importance of compliance with Notice H 2011-01 regulatory reporting requirements about DUNS number and the CCR Registration for legal entities receiving federal assistance. 

Warnings in January 2012 threatened withheld approval for Reserve For Replacement withdrawals. 

The latest missive reiterates the risk to continued payment of rental assistance subsidies for failure to comply by April 23. This applies to Section 8, PRAC, PAC and properties receiving Rent Supplement and RAP.

A March 2012 HUD field office missive cautions multifamily housing providers about the importance of compliance with Notice H 2011-01 regulatory requirements that legal entities receiving federal assistance obtain a DUNS number and maintain annual certifications for the related Central Contractor Registry (CCR).

According to the latest warning, not only are Reserve For Replacement withdrawal request likely to be held up for failure to comply, as stressed in a January 2012 reminder, but continued payment of rental assistance subsidies are at risk, and may potentially be stopped soon for properties that fail to comply by April 23, 2012.  

CCR requires owners to recertify annually, and Notice H 2011-01 requires owners to maintain their CCR registration. Rental assistance payments made under Project-Based Section 8 or Section 202 or Section 811 Project Rental Assistance Contracts (PRAC) are already explicitly covered by the notice. 

According to the field office statement, a new funding system will be implemented in May 2012 and a notice will be issued shortly to clarify that Rent Supplement and RAP contracts are also covered.

"HUD Headquarters recently ran a listing of DUNS numbers received in response to the Notice against an extract received from CCR to ensure compliance. It was discovered that there are still owners who have failed to obtain a DUNS Number and to register in the CCR system...Owners who are not in compliance with the requirements of this Notice by April 23, 2012, risk suspension of their housing assistance or rental assistance payments."

Full statement as issued by at least 1 field office on March 1:

You are reminded that in accordance with Notice H 2011-01, “Notice Requiring Owners with Project-Based Section 8 Rental Assistance Contracts or Section 202 or 811 Project Rental Assistance Contracts to Obtain Dun and Bradstreet Numbering System (DUNS) Numbers and to Register in the Central Contractor Registration (CCR),” all project owners must have obtained a DUNS number and have an active, valid registration in the Central Contractor Registration (CCR) within 60 days of the Jan. 5, 2011, publication date of the Notice and submit Attachment A, DUNS Number and CCR Registration Certification to their local HUD office to verify compliance.  The Notice further clarified that an owner’s failure to obtain a DUNS number and CCR registration within the timeframe allotted may result in the suspension of housing assistance payments or rental assistance payments.  

Rental assistance payments made under Project-Based Section 8 or Section 202 or Section 811 Project Rental Assistance Contracts (PRAC) are covered under these requirements.  The department will issue a Housing Notice shortly clarifying that this requirement also applies to RAP and Rent Supplement contracts.  

HUD Headquarters recently ran a listing of DUNS numbers received in response to the Notice against an extract received from CCR to ensure compliance.  It was discovered that there are still owners who have failed to obtain a DUNS Number and to register in the CCR system.  In order to continue to receive housing assistance payments or rental assistance payments, owners are reminded that they must comply with the requirements of Notice H 2011-01. 

Finally, CCR requires owners to recertify annually, and Notice H 2011-01 requires owners to maintain their CCR registration.  Please note that the department will be implementing a new funding system in May 2012.  As a result, owners who are not in compliance with the requirements of this Notice by April 23, 2012, risk suspension of their housing assistance or rental assistance payments.

Thank you for your cooperation in complying with these requirements. Your prompt attention to this matter is requested in order to prevent any disruption of payments under housing or rental assistance contracts.

In January 2012, several HUD field offices issued the following statement: 

Central Contractor Registration: 

  • Housing Notice H 2011-01 was issued on Jan. 5, 2011, and is targeted at providers receiving rental assistance payments made under Project-Based Section 8 or Section 202 or 811 Project Rental Assistance Contracts. So it may be a timely reminder for you all to recall that Owners must obtain a DUNS number and have an active, valid registration in CCR.

  • HUD uses your CCR registration data for payment and contract information purposes. CCR registration includes your electronic funds transfer (EFT) data and will expedite contract payments. Failure to provide and maintain current certifications will result in the inability for future funds to be obligated by HUD. This includes funds to be obligated for renewals of HAP Contracts, PAC Contracts, PRAC Contracts, & all Grant Funds issued by the department.

  • You must renew and revalidate your CCR registration at least every 12 months from the date you previously registered. However, you are strongly urged to revalidate your registration more frequently to ensure that CCR is up to date and in sync with changes that may have been made to DUNS and IRS information. If you do not renew your registration, it will expire. An expired registration will affect your ability to receive contract awards or payments, submit assistance award applications via Grants.gov, or receive certain payments from the department.
  • Please review your records to ensure that your CCR Registration number is active/renewed. If you have not provided a copy of your DUNS number and CCR Registration to HUD, please do so in accordance with Housing Notice H 2011-01 at your earliest convenience.

  • This information should be forwarded to your HUD Project Manager.

  • We will not approve Reserve For Replacement withdrawals if we do not have evidence of the DUNS number and the CCR Registration.

  • Information concerning: obtaining a DUNS number.

  • Information concerning: Central Contractor Registration (CCR). 

On Jan. 5, 2011, HUD issued Notice H 2011-01, which provides regulatory reporting requirements and guidance for all owners of properties receiving Project-Based Section 8 or Section 202/811 Project Rental Assistance Contracts (PRAC) to obtain a Duns and Bradstreet Numbering System (DUNS) number and have an active, valid registration in Central Contractor Registration (CCR) within 60 days of the publication date of this notice.   

According to the notice, an owner’s failure to obtain a DUNS number and CCR registration within the timeframe allotted may result in the suspension of housing assistance payments or rental assistance payments. 

However, during the 2011 LeadingAge Future of Aging Services Conference, as well as in numerous other public forums, HUD officials stated that they are aware of systems issues beyond HUD's control that may prevent owners/agents from completing the required registration and certification requirements.  

In these public forums, HUD officials reiterated that guidance is expected shortly to clarify policies and/or to extend the registration deadline, but have been explicit that subsidy payments will not be withheld soley for failure to certify at this time.

Be sure to read the notice to find out more about:

  • Background on Public Law 109-282, the Federal Funding Accountability and Transparency Act of 2006. 
  • Process for obtaining a DUNS Number and Registration in CCR. 
  • Using CCR and DUNS information. 

 



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