4.606 Reporting Data
Source: FAR 4.606 on acquisition.gov
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.
(a) Actions required to be reported to FPDS.
(1) As a minimum, agencies must report the following contract actions over the micro-purchase threshold, regardless of solicitation process used, and agencies must report any modification to these contract actions that change previously reported contract action data, regardless of dollar value:
(i) Definitive contracts, including purchase orders and imprest fund buys over the micro-purchase threshold awarded by a contracting officer.
(ii) Indefinite delivery vehicle (identified as an "IDV" in FPDS). Examples of IDVs include the following:
(A) Task and Delivery Order Contracts (see subpart 16.5), including–
(1) Government-wide acquisition contracts.
(2) Multi-agency contracts.
(B) GSA Federal supply schedules.
(C) Blanket Purchase Agreements (see 13.303).
(D) Basic Ordering Agreements (see 16.703).
(E) Any other agreement or contract against which individual orders or purchases may be placed.
(iii) All calls and orders awarded under the indefinite delivery vehicles identified in paragraph (a)(1)(ii) of this section.
(2) The GSA Office of Charge Card Management will provide the Government purchase card data, at a minimum annually, and GSA will incorporate that data into FPDS for reports.
(3) Agencies may use the FPDS Express Reporting capability for consolidated multiple action reports for a vendor when it would be overly burdensome to report each action individually. When used, Express Reporting should be done at least monthly.
(b) Reporting other actions. Agencies may submit actions other than those listed at paragraph (a)(1) of this section only if they are able to be segregated from FAR-based actions and this is approved in writing by the FPDS Program Office. Prior to the commencement of reporting, agencies must contact the FPDS Program Office if they desire to submit any of the following types of activity:
(1) Transactions at or below the micro-purchase threshold, except as provided in paragraph (a)(2) of this section.
(2) Any non-appropriated fund (NAF) or NAF portion of a contract action using a mix of appropriated and non-appropriated funding.
(3) Lease and supplemental lease agreements for real property.
(4) Grants and entitlement actions.
(c) Actions not reported. The following types of contract actions are not to be reported to FPDS:
(1) Imprest fund transactions below the micro-purchase threshold, including those made via the Government purchase card (unless specific agency procedures prescribe reporting these actions).
(2) Orders from GSA stock and the GSA Global Supply Program.
(3) Purchases made at GSA or AbilityOne service stores, as these items stocked for resale have already been reported by GSA.
(4) Purchases made using non-appropriated fund activity cards, chaplain fund cards, individual Government personnel training orders, and Defense Printing orders.
(5) Actions that, pursuant to other authority, will not be entered in FPDS (e.g., reporting of the information would compromise national security).
(6) Contract actions in which the required data would constitute classified information.
(7) Resale activity (i.e., commissary or exchange activity).
(8) Revenue generating arrangements (i.e., concessions).
(9) Training expenditures not issued as orders or contracts.
(10) Interagency agreements other than inter-agency acquisitions required to be reported at 4.606(a)(1).
(11) Letters of obligation used in the A-76 process.
(d) Agencies not subject to the FAR. Agencies not subject to the FAR may be required by other authority (e.g., statute, OMB, or internal agency policy) to report certain information to FPDS. Those agencies not subject to the FAR must first receive approval from the FPDS Program Office prior to reporting to FPDS.