Reporting Data
FAR 4.606 requires agencies to report most contract actions over the micro-purchase threshold to FPDS, ensuring transparency and compliance in federal procurement data reporting.
Overview
FAR 4.606 outlines the requirements for federal agencies to report contract action data to the Federal Procurement Data System (FPDS). It specifies which contract actions must be reported, exceptions, and the process for reporting other types of actions. The regulation ensures transparency and accountability in federal procurement by mandating timely and accurate data submission for contracts above the micro-purchase threshold and certain modifications, while also detailing exclusions and special reporting circumstances.
Key Rules
- Mandatory FPDS Reporting
- Agencies must report all contract actions over the micro-purchase threshold, including definitive contracts, purchase orders, and various indefinite delivery vehicles (IDVs), as well as any modifications that change previously reported data.
- Reporting Modifications and Orders
- All calls and orders under IDVs must be reported, and any changes to previously reported contract actions must also be updated in FPDS.
- Government Purchase Card Data
- GSA is responsible for providing annual purchase card data for FPDS inclusion.
- Express Reporting
- Agencies may use FPDS Express Reporting for consolidated vendor actions when individual reporting is burdensome, but must do so at least monthly.
- Reporting Other Actions
- Agencies may only report additional actions (e.g., micro-purchases, NAF transactions, leases, grants) with written approval from the FPDS Program Office.
- Exclusions from Reporting
- Certain actions, such as small imprest fund transactions, GSA stock orders, resale activities, and classified contracts, are explicitly excluded from FPDS reporting.
- Non-FAR Agencies
- Agencies not subject to the FAR must obtain FPDS Program Office approval before reporting.
Responsibilities
- Contracting Officers: Ensure all required contract actions and modifications are reported to FPDS; use Express Reporting as appropriate; seek approval for reporting non-standard actions.
- Contractors: Provide accurate contract data to facilitate agency reporting.
- Agencies: Oversee compliance, provide purchase card data, and obtain necessary approvals for non-standard reporting.
Practical Implications
- This section exists to standardize and centralize federal contract data for oversight and transparency.
- Accurate and timely reporting is critical for compliance and audit readiness.
- Common pitfalls include failing to report modifications, misunderstanding exclusions, or not obtaining required approvals for non-standard actions.