Department of the Interior Acquisition Policy Release (DIAPR) 2002-04, Amendment 2

SUBJECT: Reporting Charge Card Transactions in the Procurement Data System

1. Purpose:

This policy release provides clarification on certain information provided in DIAPR 2002-4.

2. Effective Date:

This DIAPR is effective immediately upon issuance.

3. Expiration:

This amendment remains in effect until canceled or superseded.

4. Background and Explanation:

The following information is provided to further clarify transaction reporting requirements outlined in DIAPR 2002-4.

1. DIAPR 2002-4 (March 28, 2002) rescinded DIAPR 1999-8 and modified the policy on reporting purchase card actions top allow but not require bureaus to report card purchase actions between $2,500 ($2,000 for construction) and $25,000 into the procurement data system.

2. Amendment 1 to 2002-4 (October 28, 2002) was issued to clarify action reporting per 2002-4. Primary clarifications were:

o Purchases over $500 that are not paid by the charge card (delivery orders, purchase orders, BPA calls) are not covered by the option to not report and must be reported into the procurement data system.

o Procurements for services in the SBCDP service catagories must be reported using the SF-279.

3. Recent exchanges with the FPDS-NG Project Manager (Jerry Olson) and the IAE Director (Teresa Sorrenti) on 5/6/04, related the following:

o FPDS-NG is receiving SmartPay data from the banks.

o The data are composite quarterly reports by vendor and by FIPS 95 buying organization codes. Individual transactions are not reflected.

o FPDS-NG is not yet processing the data but expects to in the future.

o Provisions are being made to ensure against double-counting of data in any resulting report.

o The dataset coming from the SmartPay process does not contain all the data elements in the FPDS-NG report dataset, therefore we must continue with duplicate reporting.

4. The land mangement bureaus recently completed a review of Emergency Equipment Rental Agreements (EERA) in the context of requiring consistent reporting across the bureaus for these purposes. After due deliberation, it was decided that, while EERAs are procurement instruments and should be reported, the burden to be expected in the short term far outweighs the benefits and EERA reporting into IDEAS will be available but will not be mandatory in FY 2004.

5. Action Required:

a. Reporting of all actions above $2,500 is required in FPDS-NG, since the functionality of the card for both purchase and payment is limited to actions of less than $2,500.

b. During FY 2004, while priority is necessarily placed on getting current year data into FPDS-NG, after the very late reporting start, all non-card actions should be given priority over card actions in FPDS-NG reporting.

c. Any action over $2,500 requires a procurement instrument.

d. Orders under the DOI Consolidated IT Buy instrument should be combined on a quarterly basis and entered into FPDS-NG as an order under an IDV.

e. Further guidance will be issued regarding FPDS-NG reporting on EERAs, etc., in FY 2005. Such reports are not required in FY 2004.