In November, Rep. Lankford (OK) introduced the Grant Reform and New Transparency (GRANT) Act of 2011. The bill requires that all grant proposals and applications, in their entirety, be posted online, available as bulk data, and fully searchable.

Awesome!

It’s up in the air whether the website described in the bill would be an entirely new website, or an updated version of Grants.gov. Currently Grants.gov is intended to be the “one stop shop” for finding grant opportunities and applying for them. Unfortunately the website has suffered from problems, both tech and funding related.

Grants.gov requires applicants to register in the Central Contractor Registry (CCR) with a tax id AND to register for a DUNS number. The GRANT act is intended to bring more rigor and oversight to the entire process of grantmaking. However, as I’ve mentioned before, this is pretty tough to do without a reliable unique identifier, and DUNS is not up to the task.

Since Grants.gov is already collecting the applicant’s Employee Identification Number in the CCR, why not use it as the identifier? Or at least include a provision that makes both of these identifiers accessible to the general public. I haven’t been able to discern why EINs are considered sensitive information, but I’m often running into statements like this on agency websites:

The above image is from the Department of Health and Human Services Tracking Accountability in Government Grants (TAGGS) search. There isn’t any information on where the “sensitive” definition comes from. But lets contrast this with a quote from another relatively new Census regulation eliminating the requirement for an SSN to be present as an identifier in the Automated Export System (AES):

The EIN is not as sensitive a form of PII as either a driver’s license or SSN…

So basically, the EIN is too sensitive to expose on federal grant records (according to HHS), but something even more sensitive (according to Census) is entrusted to clerks at any Avis or Hertz? If you keep reading in that particular regulation, you’ll also see:

Former SSN filers who want to use a Dun & Bradstreet Number (DUNS) rather than an EIN for identification purposes, must first obtain an EIN from the IRS, and apply to Dun & Bradstreet for a DUNS.

This seems to imply that D&B requires an EIN to get a DUNS number. If that’s the case, then … why are we using DUNS anyway? If we require contractors and grant recipients to get both an EIN and a DUNS, then why are we only exposing the proprietary version? And why are we paying over $50 million a year to use DUNS?