Overview
FAR 4.606 establishes the mandatory requirements, thresholds, and procedures for reporting contract actions to the Federal Procurement Data System (FPDS). It delineates which procurement actions must be recorded for transparency and which actions are excluded due to security, administrative, or jurisdictional reasons.
Key Rules
- Mandatory Reporting Threshold: Agencies must report all contract actions exceeding the micro-purchase threshold, including definitive contracts, purchase orders, and Indefinite Delivery Vehicles (IDVs).
- Modifications: Any modification that changes previously reported data must be reported to FPDS, regardless of the dollar value of the modification.
- IDV Coverage: Reporting is required for all categories of IDVs (GWACs, Multi-agency contracts, Federal Supply Schedules, BPAs, and BOAs) as well as every individual order or call placed against them.
- GSA Purchase Card Data: While individual micro-purchases are generally not reported by agencies, the GSA Office of Charge Card Management provides government purchase card data to FPDS at least annually.
- Prohibited Entries: Specific actions must not be reported, including classified information, actions that would compromise national security, GSA stock orders, and revenue-generating arrangements like concessions.
- Optional/Special Reporting: Reporting of grants, real property leases, or actions below the micro-purchase threshold requires prior written approval from the FPDS Program Office and must be segregable from FAR-based actions.
Practical Implications
- Contracting Officers must ensure that FPDS entries are updated for every qualifying modification to maintain the integrity of government-wide procurement data.
- The regulation prevents the inadvertent disclosure of sensitive information by explicitly forbidding the entry of classified contract data or information that could compromise national security into the public-facing system.