Department of the Interior Acquisition Policy Release (DIAPR) 2007 - 01

SUBJECT: Ensuring Accurate Procurement Data Reporting to the Federal Procurement Data System-Next Generation (FPDS-NG)

REFERENCE: Federal Acquisition Regulation (FAR) Subpart 4.6, "Contract Reporting"; DIAPR 2002-04 and Amendments I and 2, "Reporting Charge Card Transactions in the Procurement Data System"; and, DIAPR 2004-07, "Ensuring Accurate Procurement Data Reporting to the FPDS-NG"

1. Purpose:

This policy release is issued to establish certification requirements for bureau submissions to FPDS-NG in order to ensure the timeliness and accuracy of data entry.

2. Effective Date:

Effective immediately upon issuance.

3. Expiration Date:

This DIAPR supersedes DIAPR 2004-7 "Ensuring Accurate Procurement Data Reporting to the FPDS-NG" and DIAPR 2002-04 and all amendments thereto, "Reporting Charge Card Transactions in the Procurement Data System" and remains in effect until canceled or superseded.

4. Background and Explanation:

FAR Subpart 4.6 requires agencies to report all procurement actions that exceed the micro-purchase threshold (i.e., currently $3,000) and all modifications to those transactions regardless of dollar value to FPDS-NG. Additionally, as a participant in the Small Business Competitiveness Demonstration Program, the Department of the Interior (DOI) is required to report all actions, regardless of dollar value, made in the designated industry groups.

The following actions are NOT reported to FPDS-NG:

• Financial assistance actions e.g. grants, cooperative agreements, subsidies, contributions, P.L. 93-638 actions, etc.
• Imprest fund transactions, SF 44 purchases, and training authorizations. Purchase card transactions with a total cumulative value less then the micro-purchase threshold ($3,000) are not required to be reported but an agency may elect to do so.
• Interagency agreements with other federal agencies (e.g. Tennessee Valley Authority, GPO transactions, etc.), independent federal establishments (e.g. ExportJImport Bank of the US), or federally chartered sources (e.g. Howard University or the Smithsonian Institution).
• Government Bills of Lading and Government Transportation Requests.
• Interagency agreements with other federal agencies (e.g. Tennessee Valley Authority, GPO transactions, etc.), independent federal establishments (e.g. Export/Import Bank of the US), or federally chartered sources (e.g. Howard University or the Smithsonian Institution).
• Government Bills of Lading and Government Transportation Requests.
• Actions using predominantly non-appropriated funds, except pursuant to 2b above.
• FED STRIP and MILSTRIP requisitions.
• Actions involving transfer of supplies within and among agencies and sub agencies.
• Orders from GSA Stock and GSA Consolidated Purchase Program (e.g., GSA Advantage)
• Civilian agencies shall not report actions for petroleum or petroleum products ordered against a Defense Logistics Agency Indefinite Delivery Contract. (See Part III, C.3d.)

Data from FPDS-NG is used by the White House, Congress, the Government Accountability Office, other Federal executive agencies, the general public, the Small Business Administration (SBA) in calculating agency goals, and DOI managers, as a basis for decisions on a variety of topics. Further, OMB Circular A-123 "Management's Responsibility for Internal Control" mandates implementation of internal controls to ensure, among other objectives, that reliable, complete, and timely data are maintained.

5. Action Required:

a. All procurement actions that have the potential of exceeding the micro-purchase threshold ($3,000), including those made with the Government purchase card, must be entered into FPDSNG. All procurement actions that fall under the Small Business Competitiveness Demonstration Program must be reported to FPDS-NG regardless of dollar value.

b. Data should be entered into FPDS-NG as close to real time as possible, ideally, prior to the obligation of the contract action. Data entry, review, and approval in FPDS-NG must be accomplished within three days of the procurement action being obligated.

c. Reporting of all actions must be done by the responsible Contracting Officer, Contract Specialist or Purchasing Agent, or other personnel who are fully trained in procurement and subjects involved in the reporting process and are able to efficiently and accurately determine the correct response to all data issues. The Contracting Officer must, at the very least, review and approve within the system the data entered into FPDS-NG.

d. Particular attention must be paid to the accuracy of each and every data element submitted by reporting and reviewing personnel, especially the business size status and all socioeconomic information, such as Service Disabled Veteran Owned Businesses (SDVOB), which should be derived from a review of the vendor's On-line Representations and Certifications application. Correct entry of all dates, dollar amounts, selection of the appropriate PSC and NAICS codes, Contracting Officer's size determination, and project descriptions that clearly explain what is being procured, are other examples of focus areas.

e. Each bureau shall establish a procurement data quality control plan involving, as a minimum, the following:

• Identification of the bureau FPDS-NG system administrator. This individual will serve as a liaison between the Office of Acquisition and Property Management (PAM) and the bureau FPDS-NG users.
• The means by which the bureau intends to capture any unique FPDS-NG reporting requirements of non-DOl entities, if applicable.
• The proposed corrective actions the bureau will implement in response to persistent inaccurate, late, and\or non-existent reporting.
• The bureau's review process at each level of the organization. For example:

o The Contracting Officer responsible for signing the contract ensures that an FPDS-NG record has been created for the action and that all the information is accurate. This review should take place prior to obligation of the action.
o The manager\supervisor for the contracting activity reviews the standard reports available in FPDS-NG no less than bi-weekly to ensure all procurement actions that have the potential of a cumulative total exceeding the micro-purchase threshold have a corresponding FPDS-NG entry that is accurate and complete.
o At each succeeding supervisory\management level data is reviewed and certifications are provided that all applicable data is entered into FPDSNG and is accurate.
o Standard report data is periodically reviewed for common errors\miscodings so that targeted training\clarification can be provided.

The bureau procurement data quality control plan must be submitted to PAM within one month of this policy's issuance date.

f. Each bureau procurement chief shall submit to the Director, PAM, a certification of the completeness, currency and accuracy of the prior fiscal year data, no later than October 13th of each year. The certification should confirm that all applicable actions were entered, are accurate, and were reviewed\approved by the responsible Contracting Officer. The certification should also confirm that the bureau procurement data quality control plan was followed. The certification should further quantify and explain:

a. any known errors or unresolved anomalies remaining in the data;
b. goals for the current fiscal year; and
c. steps being taken to further improve the quality (completeness and accuracy) as well as the timeliness of the data.

6. Additional Information:If you have questions about this matter, please contact Kate Oliver at (202) 208-3345.