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APM 2008-05: Contract Reporting

Acquisition Policy Memorandum No. 2008 – 05

11-26-08

To:                        Heads of Contracting Activity                         

From:                    Martin J. Brown /s/ 
                             Senior Procurement Executive

Subject:                 Contract Reporting

Effective Date:       Immediately

1. Purpose:  This memorandum (a) implements the Office of Federal Procurement Policy’s (OFPP) initiative to improve the quality and timeliness of the Contract Award Report (CAR) information stored in the Federal Procurement Data System—Next Generation (FPDS-NG), in HHS’ Departmental Contract Information System (DCIS), and in USASpending.gov; (b) promulgates interim acquisition guidance on contract reporting (Enclosure 1), pending incorporation in the HHS Acquisition Regulation (HHSAR); and (c) establishes minimum standards for OPDIV reviews of DCIS data (Enclosure 2).  

2. Background:  Within HHS, CAR information is commonly called DCIS data--for the HHS database which stores it.  Except for approximately thirty HHS-unique pieces of information, identical information resides in GSA’s FPDS-NG database; and thirteen pieces of the same contract information, plus a Treasury code, are stored in USASpending.gov. 

In FY2007, OFPP, concerned about Congressional and media criticism of the quality of FPDS-NG data, required agencies which submit CARs to FPDS-NG to review their data for accuracy.  HHS’ subsequent formal study of its DCIS data revealed a considerable number of inaccuracies.  At about the same time OFPP took steps to implement the Federal Funding Accountability and Transparency Act (Transparency Act), which required federal agencies to post information about federal contracts to a single accessible and searchable website. USASpending.gov is the result. 

Based on feedback on its FY2007 guidance, OFPP developed an initiative to improve the quality of the CAR data in FPDS.  Consistent with OFPP’s data improvement initiative, HHS proposed to:

  1. Update its HHSAR subpart 304.6 on Contract Reporting (enclosed);
  2. Update its DCIS Users’ Manual (http://dcis.hhs.gov/manual.html);
  3. Encourage its OPDIVs to develop and implement OPDIV-unique data improvement initiatives, e.g. specialized training, CAR checklists, peer reviews, etc.; and
  4. Continue its reviews of CAR data in DCIS, based on its formal FY2007 study.   

3. Applicability:  HHS’ initiative to improve the quality and timeliness of its CAR data in DCIS and FPDS-NG applies to: (a) all HHS contract specialists, contracting officers, purchasing agents, consultants and clerks who consolidate CAR information and input it to PRISM, Integrated Contracts Expert System (ICE), DCIS, and FPDS-NG; (b) all analysts, managers, and HCAs who validate and certify DCIS data; and (3) HHS and OPDIV managers, representatives, and focal points for DCIS and FPDS-NG, including the DCIS Configuration Committee.

4. DCIS Data Verification and Validation:  HHS acquisition officials and staff must submit CAR data to DCIS and FPDS-NG accurately and timely.  To ensure accuracy, OPDIVs will compare selected DCIS records with contract files, in accordance with “Minimum Standards for OPDIV Quality Review of Departmental Contracts Information System Data for FY2009” (Enclosure 2, with attachments).  OPDIVs will forward the results of their comparisons to ASAM/OAMP quarterly. 

5. DCIS Business Rule:  Generally, Federal Acquisition Regulation (FAR) Subpart 4.6, “Contract Reporting,” requires submitting a CAR for each contract action whose value exceeds the micropurchase threshold, currently $3000.  When using a contract writing system which is integrated with FPDS-NG, validation of the report information[1]  must precede award of the action (FAR 4.604(b)(2)).  Otherwise, reports must be submitted to FPDS-NG within three business days of award (FAR 4.604(b)(3)).

At HHS, this means all contracting offices that use automated contract writing systems which interface with FPDS-NG - as CMS, NIH and HCAS occurrences of PRISM do - must validate report data before awarding the associated contract action.  Contracting offices without automated contract writing systems or whose systems do not interface with FPDS, e.g., CDC’s ICE, must submit their reports to FPDS-NG within three business days of award.

6. FPDS-NG Data Certification:  No later than December 15th of each year, HCAs shall certify the extent to which FPDS-NG contains complete and accurate reports for all of their contract actions greater than $3000 awarded in the previous fiscal year.  Based on HCA certifications, the HHS Chief Acquisition Officer shall certify the completeness and accuracy of HHS’ FPDS-NG data, including Transparency Act data, to OFPP and GSA no later than the following January 5th.

Enclosures (Enclosure 2 has 3 attachments)



[1] FPDS accepts validated report information automatically.  Invalid data is returned to the sender.  Thus, validation includes submission of the data, and both must occur prior to award of a reportable action.