Procedures
FAR 4.605 mandates strict procedures for assigning and reporting unique identifiers and codes in federal contract actions to ensure accurate, governmentwide data integrity.
Overview
FAR 4.605 outlines the procedures for assigning and reporting key identifiers and codes in federal contract actions, ensuring accurate and consistent data entry into the Federal Procurement Data System (FPDS). It establishes requirements for the use of Procurement Instrument Identifiers (PIIDs), unique entity identifiers, and office codes, as well as the limited use of generic entity identifiers under specific circumstances. The section also addresses special reporting for actions funded by the American Recovery and Reinvestment Act.
Key Rules
- Procurement Instrument Identifier (PIID) Uniqueness
- Agencies must ensure each PIID is unique governmentwide for at least 20 years and follow FPDS instructions for reporting.
- Unique Entity Identifier Reporting
- Contracting officers must report the unique entity identifier for the successful offeror, matching the name and address in the contract and SAM registration, using specified FAR provisions.
- Use of Generic Entity Identifiers
- Generic identifiers are only allowed in limited cases (e.g., certain small-value contracts, contracts with individuals overseas, or when disclosure could endanger parties), and do not replace the requirement for a unique entity identifier when applicable.
- American Recovery and Reinvestment Act Reporting
- Special FPDS instructions must be followed for contracts funded by the Act.
- Office Codes
- Agencies must use the Activity Address Code (AAC) for contracting and funding office codes as of March 31, 2016.
Responsibilities
- Contracting Officers: Ensure correct assignment and reporting of PIIDs, unique entity identifiers, and office codes; use generic identifiers only when authorized; follow special reporting for Recovery Act funds.
- Contractors: Provide accurate unique entity identifiers and ensure SAM registration matches contract information.
- Agencies: Maintain processes for PIID uniqueness and proper office code assignment; oversee compliance with reporting requirements.
Practical Implications
- Accurate reporting is critical for transparency, data integrity, and compliance in federal procurement.
- Errors in identifiers or codes can lead to reporting issues, audit findings, or delays in contract processing.
- Contractors must ensure their SAM registration is current and matches contract details to avoid administrative issues.