Overview
Subpart 4.6 prescribes the uniform requirements for reporting federal contract actions to the Federal Procurement Data System (FPDS). Its primary purpose is to ensure transparency in government spending, provide a basis for reporting to Congress and the President, and measure the achievement of socioeconomic goals such as small business participation and sustainable acquisition.
Key Rules
- Reporting Threshold: Agencies must report all unclassified contract actions exceeding the micro-purchase threshold (MPT) and any subsequent modifications to those actions regardless of dollar value.
- Public Accessibility: In accordance with the Federal Funding Accountability and Transparency Act (FFATA) of 2006, all unclassified federal award data must be publicly accessible via FPDS.
- Timelines:
- Standard contract action reports (CARs) must be completed within three business days after contract award.
- Actions awarded under emergency authorities (FAR 6.302-2 or Subpart 18.2) must be reported within 30 days.
- Updates to contractor size status (rerepresentation) or SBA protest decisions must be entered within 30 days.
- Unique Identifiers: Every reported action must have a Procurement Instrument Identifier (PIID) that is unique government-wide for at least 20 years. Contractors must be identified by a Unique Entity Identifier (UEI) synchronized with the System for Award Management (SAM).
- Reportable vs. Non-Reportable: While definitive contracts and Indefinite Delivery Vehicles (IDVs) are mandatory, certain actions like grants, real property leases, and transactions involving classified information are specifically excluded from FPDS reporting.
Responsibilities
- Senior Procurement Executive (SPE): Responsible for developing and monitoring agency-wide processes to ensure reporting is both timely and accurate.
- Contracting Officer (CO): Holds the primary responsibility for the completion and accuracy of individual CARs. They must confirm accuracy before award and ensure the CAR is finalized in FPDS.
- Chief Acquisition Officer (CAO): Must submit an annual certification to the GSA within 120 days of the fiscal year-end, verifying the integrity and completeness of the agency's data for the preceding year.
- Integrated Award Environment (IAE) Program Office: Maintains authorized generic entity identifiers for specific exempted scenarios (e.g., small awards to students or overseas vendors).
Practical Implications
- Socioeconomic Tracking: FPDS data is the "source of truth" for whether an agency is meeting its small business and sustainable technology goals. If a CAR is coded incorrectly, an agency may not receive proper credit for a small business award.
- Administrative Burden: The "three-business-day" rule creates a tight administrative window for Contracting Officers, often requiring the CAR to be drafted simultaneously with the award documents to avoid non-compliance.
- Public Scrutiny: Because this data is public (via sites like USAspending.gov), contractors and competitors use this information for market research. Inaccurate reporting can lead to business intelligence errors or disputes regarding an agency's spending patterns.
- Assisted Acquisitions: In interagency deals, the "requesting agency" (the one providing the money) gets the socioeconomic credit, even if a different "servicing agency" handles the actual procurement, provided the correct codes are entered in the CAR.