Overview
FAR 4.604 outlines the hierarchy of responsibility for ensuring that contract data is accurately and timely reported to the Federal Procurement Data System (FPDS), ranging from the individual Contracting Officer to agency leadership.
Key Rules
- Contracting Officer (CO) Responsibility: The CO who awards the action is directly responsible for the accuracy and completion of the Contract Action Report (CAR). A CAR is not considered "complete" if it remains in a draft or error status.
- Standard Reporting Timeline: The CO must confirm CAR accuracy prior to award and must complete the entry in FPDS within three business days after the award.
- Emergency/Urgency Exceptions: For actions involving unusual and compelling urgency or emergency acquisitions, the reporting window is extended to 30 days after award.
- Size Status Updates: COs must update a contractor's size status in FPDS within 30 days of receiving a formal rerepresentation or a final SBA size protest decision.
- Administrative Oversight: Senior Procurement Executives must monitor the reporting process, and Chief Acquisition Officers must submit an annual certification of data accuracy to the GSA within 120 days of the fiscal year's end.
Practical Implications
- COs cannot treat FPDS entry as a back-office task to be handled weeks later; it is a high-priority compliance item that must be integrated into the immediate post-award workflow.
- Because agency leadership must certify this data annually, there is significant internal pressure on contracting activities to eliminate "draft" CARs and ensure data integrity for small business goal tracking.