Department of the Interior Acquisition Policy Release (DIAPR) 2008-08
SUBJECT: Ensuring Accurate Procurement Data Reporting to the Federal Procurement Data System-Next Generation
Reference: Federal Acquisition Regulation (FAR) Subpart 4.6, "Contract Reporting"; DIAPR 2002-04 and Amendments 1 and 2, "Reporting Charge Card Transactions in the Procurement Data System"; and, DIAPR 2004-07, "Ensuring Accurate Procurement Data Reporting to the FPDS-NG"
The following actions are NOT currently reported to FPDS-NG:
• Financial assistance actions; e.g., grants, cooperative agreements, subsidies" contributions, P.L 93-638 actions.
• Imprest fund transactions, SF 44 purchases, and training authorizations. Purchase card transactions with a total cumulative value less than the micro-purchase threshold 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), 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.
• 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).
• Actions for petroleum or petroleum products ordered against a Defense Logistics Agency Indefinite Delivery Contract.
It is imperative that data submissions to the FPDS-NG be timely and correct for many reasons. The Federal Funding Accountability and Transparency Act (FFATA) was signed on September 26,2006. One requirement of FFATA is that federal contract data be made available to the public via a single, searchable website. FPDS-NG data is forwarded to this website (www.usaspending.gov) on a daily basis. Data from the 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.
(1) All procurement actions that have the potential of exceeding the micro-purchase threshold, including those made with the Government purchase card must be entered into FPDS-NG. All procurement actions that fall under the Small Business Competitiveness Demonstration Program must be reported to FPDS-NG regardless of dollar value.
(2) Data must be entered into FPDS-NG and confirmed for accuracy as close to real time as possible. When an action is being submitted from a contract writing system, it must be confirmed for accuracy prior to its release for award; otherwise, entry, review, and approval must be accomplished no later than three days after the procurement action has been signed.
(3) Contract actions must be entered into FPDS-NG by a responsible Contracting Officer, Contract Specialist or Purchasing Agent, who has been fully trained in procurement and subjects involved in the reporting process and is able to efficiently and accurately determine the correct response to all data elements.
(4) Each action entered into FPDS-NG must be reviewed and approved by the Contracting Officer who signed the procurement action.
(5) Corrections to and deletions of FPDS-NG actions must be made by the administering Contracting Officer. The following exceptions apply:
a. Changes and/or deletions that can not be made by the administering Contracting Officer and require intervention by FPDS-NG support. In this case, the bureau FPDS-NG administrator must contact the DOI FPDS-NG administrator to identify any issues where they feel this applies. If appropriate, the DOI FPDS-NG administrator will request assistance from FPDS-NG Support.
b. When a unique circumstance exists making paragraph (4) above impractical; e.g., mass corrections, and a waiver has been obtained from the DOI FPDS-NG administrator.
6) Reporting and reviewing personnel must pay particular attention to the accuracy of each and every data element, especially the business size status, and socioeconomic information, such as Service Disabled Veteran Owned Businesses, 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.
B. Procurement Data Quality Control Plan
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-DOI entities.
• The corrective actions the bureau will implement in response to persistent inaccurate, late, and/or non-existent reporting.
• How individuals will be held accountable for data accuracy. Bureaus must demonstrate that there will be real consequences for persistent inaccurate, late, and/or non-existent reporting. Bureau Procurement Chiefs, managers, supervisors, and Contracting Officers must all be held equally accountable.
• 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 and matches the contract file. This review must 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 that all applicable data is entered into FPDS-NG and is accurate are provided.
o Standard report data is periodically reviewed for common errors/miscoding so that targeted training/clarification can be provided.
Bureau procurement data quality control plans must be reviewed, updated, and submitted to PAM within one month of this policy's issuance date. It must also be reviewed, updated, and submitted to PAM annually no later than October 30. Procurement data quality control plans must be signed by the Bureau Procurement Chief.
C. Review and Certification
Using current OMB guidelines, PAM will provide each bureau with a projected FPDS-NG contract action report sample size. The projected sample size will be provided to the bureaus no later than November 1 of each year and must be used by bureaus to plan their upcoming quarterly and annual reviews.
(1) Quarterly Reviews and Certifications.
a. Each bureau must perform quarterly reviews of its FPDS-NG data.
b. All data elements for each FPDS-NG action must be validated against the associated contract file.
c. The review of an FPDS-NG action report must not be conducted by the approving Contracting Officer or other individual who prepared the action.
d. Using the sample size projection for the applicable quarter, each bureau will select a sample of its actions that proportionally reflects the types of actions; e.g., Purchase Order, Definitive Contract, entered into FPDS-NG during that quarter. The bureau will then identifY for each type of action, the actions with the highest obligation amount. Contracting office, region, or other criteria shall not be used to determine the make-up of the bureau's sample.
e. The review of each action must be documented and a detailed Quarterly Reviewed Actions Report must be submitted to PAM with the Bureau Procurement Chiefs quarterly certification document. The report shall include for each action reviewed, at a minimum: Agency, Office, PIID, modification number, Referenced IDV PIID, Type of Action, Obligation Amount, Created by User, Reviewer, Date Reviewed, and the FPDS-NG key data elements specified in Exhibit 1, Attachment C. The report must indicate if any errors found within these data elements were caused by the user, FPDS-NG, or whether there were other contributing factors; e.g., CCR. A description of the error(s) found, corrective action(s) taken, and projected date for corrective action must also be included.
f. Elements that are initially found to be incorrect during a quarterly review must be reported as such, and must never be changed to "correct".
g. Data elements that cannot be validated must be considered incorrect. This includes data elements that match data in the contract file that the reviewer determines to be incorrect.
h. When action reviews have been completed and documented, an overall accuracy rate and accuracy rates for each of the FPDS-NG key data elements must be calculated in accordance with Exhibit 1, Attachment B, and documented on the Accuracy Rates form at Exhibit 1 Attachment C.
i. Each Bureau Procurement Chief must certifY the completeness, currency, and accuracy of FPDS-NG data by completing and submitting the quarterly certification document found at Exhibit 1 to the Director, PAM, no later than 15 days after the end of each quarter. The Quarterly Reviewed Actions Report and completed Quarterly Data Element Accuracy Rate's form must be included with the quarterly certification as attachments. The certification must confirm that all applicable actions were approved by the responsible Contracting Officer and are accurate. The certification must also confirm that the bureau procurement data quality control plan was followed. The certification must further quantifY and explain:
• Any known errors or unresolved anomalies remaining in the data;
• Goals for the current fiscal year; and
• Steps being taken to further improve the quality (completeness and accuracy) as well as the timeliness of the data.
(2) Annual Review and Certification
a. Each bureau shall review it's Quarterly Reviewed Actions Reports to verify that all entries are accurate, outstanding corrective actions have been completed, incorrect entries identified within key data elements were identified correctly as system, user, or other, and a description of the error(s) found and corrective action(s) taken have been included. After this review the quarterly reports must be consolidated into one Annual Reviewed Actions Report and submitted to PAM with the Bureau Procurement Chiefs annual certification.
b. Elements that were found to be incorrect during quarterly reviews must be reported as such on the Annual Reviewed Actions Report, even if the action has since been corrected.
c. After the data included in the Quarterly Reviewed Actions Report has been verified and consolidated into the Annual Reviewed Actions Report, annual data element accuracy rates must be calculated in accordance with Exhibit 2, Attachment B, and documented on the Accuracy Rates form at Exhibit 2 Attachment C.
d. Each Bureau Procurement Chief must certify the completeness, currency, and accuracy of FPDS-NG data by completing and submitting the annual certification document found at Exhibit 2 to the Director, PAM, no later than October 15. The Annual Reviewed Actions Report and completed Annual Data Element Accuracy Rate's form must be included with the annual certification as attachments. The certification must confirm that all applicable actions were approved by the responsible Contracting Officer and are accurate. The certification must also confirm that the bureau procurement data quality control plan was followed. The certification must further quantify and explain:
• Any known errors or unresolved anomalies remaining in the data;
• Goals for the current fiscal year; and
• Steps being taken to further improve the quality (completeness and accuracy) as well as the timeliness of the data.
| / signed Debra E. Sonderman, Director Office of Acquisition and Property Management |