Procedures
FAR 4.605 requires strict adherence to unique identifiers and accurate reporting in FPDS to ensure transparency and traceability in federal contracting.
Overview
FAR 4.605 outlines the procedures for reporting contract actions in the Federal Procurement Data System (FPDS), focusing on the use of unique identifiers for procurement instruments and entities. It mandates that agencies ensure each Procurement Instrument Identifier (PIID) is unique governmentwide for at least 20 years and that contracting officers report the unique entity identifier (UEI) for successful offerors, matching the name and address as registered in the System for Award Management (SAM). The section also details limited circumstances under which a generic entity identifier may be used, such as for certain low-value contracts or when disclosure could endanger individuals or missions. Additional requirements include proper coding for contracts funded by the American Recovery and Reinvestment Act and the use of Activity Address Codes (AAC) for office identification in FPDS reporting.
Key Rules
- Unique PIID Requirement
- Agencies must ensure each PIID reported to FPDS is unique governmentwide and remains so for at least 20 years from contract award.
- Unique Entity Identifier (UEI) Reporting
- Contracting officers must report the UEI for the successful offeror, ensuring it matches the offeror’s SAM registration and contract documentation.
- Use of Generic Entity Identifiers
- Generic entity identifiers are only permitted in specific, limited scenarios (e.g., certain low-value contracts, contracts with individuals overseas, or when disclosure poses a risk), and do not override the requirement for a UEI if otherwise required.
- American Recovery and Reinvestment Act Reporting
- Contracting officers must follow FPDS instructions to identify actions funded by the Act.
- Office Codes
- Agencies must use the correct AACs for contracting and funding offices in FPDS reporting.
Responsibilities
- Contracting Officers: Ensure accurate and compliant reporting of PIIDs, UEIs, and office codes in FPDS; use generic identifiers only when authorized and document determinations as required.
- Contractors: Provide accurate UEI information as registered in SAM; comply with solicitation provisions regarding entity identification.
- Agencies: Maintain processes for unique PIID assignment and ensure office codes are properly assigned and reported.
Practical Implications
This section ensures data integrity and traceability in federal contract reporting, supporting transparency and accountability. Contractors must maintain accurate SAM registrations, and contracting officers must be diligent in following reporting protocols. Common pitfalls include mismatched UEI data, improper use of generic identifiers, and incorrect office coding, all of which can delay contract actions or result in compliance issues.