Overview
This section outlines the mandatory administrative procedures for reporting contract actions to the Federal Procurement Data System (FPDS), focusing on the standardized identification of procurement instruments, participating entities, and government offices. It establishes the technical requirements for data integrity to ensure government-wide traceability and accountability in federal spending.
Key Rules
- PIID Uniqueness: Agencies must ensure that every Procurement Instrument Identifier (PIID) is unique across the entire Federal Government and remains unique for at least 20 years from the date of award.
- Unique Entity Identifier (UEI): Contracting officers must report the UEI for the successful offeror, ensuring it matches the name and address registered in the System for Award Management (SAM).
- Generic Entity Identifiers: Use is strictly limited to specific scenarios, such as awards under $40,000 to students or certain overseas contractors, or when public identification of the party could endanger the mission or individuals.
- Security Determinations: If a generic identifier is used for security/endangerment reasons, the contracting officer must include a written justification in the contract file.
- Standardized Office Codes: Agencies are required to use Activity Address Codes (AACs) to identify both the issuing contracting office and the office providing the majority of the funding.
- Recovery Act Tracking: Specific instructions must be followed to identify any actions funded by the American Recovery and Reinvestment Act of 2009.
Practical Implications
- Data Validation: Contracting officers must perform due diligence to ensure the UEI provided in the offer matches the SAM registration exactly, as discrepancies will cause reporting errors in FPDS.
- Auditability: The 20-year uniqueness rule for PIIDs and the mandatory use of AAC codes ensure that federal spend can be accurately audited and tracked across different agencies and fiscal years.