“The Project On Government Oversight (POGO) provides the following public comment to “Federal Acquisition Regulation; Unique Identification of Entities Receiving Federal Awards,” (80 Fed. Reg. 72035, November 18, 2015). As an independent nonprofit organization committed to achieving a more accountable and transparent federal government, POGO has a longstanding interest in federal contracting issues and in creating a non-proprietary unique identification numbering system for federal contractors and grantees. The federal government awards over a trillion dollars each year in contracts and grants, but the only way the government can track the recipient entities is by using a proprietary identification number. This requires the government to pay Dun & Bradstreet millions in licensing fees to use their Data Universal Numbering System (DUNS). In 2014, the Recovery Accountability and Transparency Board, the federal agency overseeing stimulus and Hurricane Sandy spending, decided not to renew that licensing agreement, which means the government and the public lost identifier data on billions of dollars spent under the Recovery Act. POGO supports the proposal to end Dun & Bradstreet’s monopoly by amending the Federal Acquisition Regulation to redefine unique entity identifiers. While we understand how the federal government came to rely on the DUNS identifiers, the fact remains that the DUNS system was not developed to serve as a government identifier and thus fails to serve the needs of the government and the public. It is long past time to replace DUNS with a better system. The DUNS number should be replaced with a non-proprietary, unique entity identifier that will link parent companies with all of their subsidiaries. This system should reveal all domestic and foreign relationships, including parents, subsidiaries, joint-ventures, partnering arrangements, and mentor programs.”