Difference between revisions of "FPDS FAQ"

WHAT’S IN FPDS

What’s reported to FPDS?

Contracts whose estimated value is $10,000 or more. Every modification to that contract, regardless of dollar value, must be reported to FPDS.

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If I have a BPA or IDIQ with no money obligated on it do I need to report to FPDS?

Yes. In order for the BPA call or orders to be entered into FPDS the instrument they are placed against (i.e., the BPA or IDIQ) must first be entered into FPDS.

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Are grants and cooperative agreements reported to FPDS?

No.

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What can be reported to FPDS?

Agencies will report on all contract actions using appropriated funds as specified in FAR 4.6. AbilityOne (formerly JWOD Nonprofit Agency or Sheltered Workshop awards) and UNICOR (Federal Prison Industries) awards are reportable as they are not interagency agreements.

Below is a partial list of types of awards reportable to FPDS. See FAR 4.606 for the full list. Agencies will report unclassified information on all contract actions using appropriated funds including, but not limited to, those made:

• With replenishable stock and revolving funds
• With appropriated funds transferred from one executive agency to another where the servicing agency contracts for the supplies or services
• With appropriated funds obligated pursuant to the provisions of PL 85-804
• By one agency to another
• For supplies and equipment
• For construction, alteration or maintenance of real property
• For services, including research and development and Utilities
• AbilityOne (formerly JWOD Nonprofit Agency or Sheltered Workshop awards)
• Telecommunications from regulated carriers; and
• Federal Prison Industries, i.e. UNICOR awards (orders from GSA stock for UNICOR products are not reportable)
• Agencies will report all contract actions made with funds held in trust accounts for foreign governments or procurements for foreign governments regardless of the nature of the funds. (The term “foreign governments include international organizations.)

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What is not reported to FPDS?

Agencies shall not report:

• Financial assistance actions e.g. grants, cooperative agreements, subsidies, and contributions except for those Agencies who have a special module to accumulate information on these types of actions.
• Imprest fund transactions, SF 44 purchases, training authorizations, and micro-purchases obtained through the use of the government purchase card. The term “micro-purchase” has the same meaning as set forth in FAR 2.101.
• Interagency agreements with other federal agencies (e.g. Tennessee Valley Authority), 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 funds held in trust accounts mentioned.
• FEDSTRIP and MILSTRIP requisitions.
• Actions involving transfer of supplies within and among agencies and sub-agencies.
• Orders from GSA Stock and GSA Consolidated Purchase Program.

Additionally, both civilian agencies and DoD will not report actions for petroleum or petroleum products ordered against a Defense Logistics Agency Indefinite Delivery Contract.

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What is FPDS not designed to collect?

The following data elements will not be found in FPDS. Contracting officers can’t put this information in FPDS even if they want to. Most of this data resides at the individual contracting office.

• Subcontracting data from either the government or the prime contractors with whom we do business. The government does have a method to collect this data at www.esrs.gov. The two data sources work together.
• Contract funding data outside of estimated totals and funds obligated on an action.
• Contract accounting data.
• Contract line item data is not in FPDS. This includes specific information about the CLIN. There is no NAICS information at the CLIN level, no CLIN description, no CLIN funding data, and no appropriation data at the CLIN level.
• No administration details including contracting officer’s technical representative names, wage determinations data, and details about the services via the contract number.
• Details of an entity's employee or staffing levels.
• Management plans.
• Statements of work or objectives.
• Terms and conditions of a contract.
• Deliverables.
• Entitlement expenditures including health, drug, Medicare, or insurance payouts. However, contracts about the management of these programs are required to be submitted.
• Contractor proposals from the awardee or any other interested party.
• Information about any parties excluded from the procurement.

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What are federal departments and agencies doing to assure that the data they submit to FPDS are as accurate as possible?

At the direction of the Office of Federal Procurement Policy (OFPP), GSA requires an annual certification be complement by each department/agency that states the completeness and accuracy percentages of their data contained in the FPDS

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Can I obtain the entire contract file from FPDS? If not, where can I get that information?

No. FPDS contains summary level information about the contract. You must contact the Contracting Officer for information about the contract file, proposals, etc. and reference the Freedom of Information Act (FOIA).

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Where can I see each of the items that were purchased on a contract?

We refer to this level of detail as the "contract line item" or the "contract line item number" (CLIN) data. CLIN data is not reported to FPDS. Usually CLIN data is available to the public through a formal FOIA request made to the contracting officer.

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What if I get locked out after 5 unsuccessful attempts at logging in?

Your FPDS user 'profile' account can still become locked out after 5 unsuccessful attempts either via Business Services or through authenticated ATOM feeds. If for any reason the FPDS system alerts you that your user 'profile' account has been locked out, please contact your Department or Agency FPDS System Administrator to enable your account.

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PURCHASE CARD

Should I report purchase card buys to FPDS?

Any purchase card buy over the micro-purchase threshold requires a procurement instrument, and per the Federal Acquisition Regulations, any procurement action over the micro-purchase threshold must be reported to FPDS. Therefore, yes you would need to report purchase card buys over the micro-purchase threshold to FPDS.

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What does "Purchase Card Used as Method of Payment" mean?

The order or contract provides for payments to the entity to be made through the use of the purchase card. These are “charges” backed by a contract vehicle. It allows the government and the entity to avoid the use of expensive invoices. A purchase card used for an amount over the micro-purchase threshold automatically becomes a method of payment.

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USASPENDING.GOV

What’s the difference between FPDS and USASpending.gov?

FPDS provides procurement data to USASpending.gov. USASpending.gov contains information about procurements, grants, loans.

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Why is the data different in USASpending.gov?

USASpending.gov is not currently pulling procurement data from FPDS in real time. USASpending.gov is updated with FPDS data on a nightly basis.

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ENTITY INFORMATION

Where does entity information come from?

All entity information comes from the SAM unless there is a SAM exception that applies. The URL for SAM is www.sam.gov.

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What is the SAM?

The System for Award Management (SAM) is a Federal Government owned and operated free web that can be used for entering and retrieving the following information.
• Register to do business with the U.S. government
• Update or renew your entity registration
• Check status of an entity registration
• Search for entity registration and exclusion records

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If an entity is in SAM, does ALL entity information then come from SAM?

All entity name, address, socioeconomic and Unique Entity ID (SAM) data come from the SAM. The only exception is the Contracting Officer’s Determination of Business Size which is either entered by the person entering the contract or is propagated to a modification from the base contract or propagated from the referenced IDV in the case of a Delivery/Task order or BPA Call.

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What if my entity is not in the SAM?

Per Federal Acquisition Regulations the entity must be registered in SAM. Please see FAR 4.1102 for exceptions. An entity must be registered in SAM if your solicitation contains the SAM clause. If your solicitation contains the SAM clause then see FAR 4.1103 for steps that must be taken if your entity is not registered in SAM. Unique Entity ID (DUNS) are still required for any entity, even if they are not registered in SAM.

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My entity is considered a 'foreign entity', so they don’t need to register in SAM, correct?

No. FAR 4.1102(a)(5) states that this exemption only applies to awards made to foreign entities where the place of performance is outside the United States, AND if it is impractical to obtain SAM registration.

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I see the entity entry in SAM but I can’t find this same entity when I do an entity search in FPDS while entering my contract. Why?

First ensure that the Unique Entity ID (DUNS) entered is correct. If it is correct, find out if the entity has just registered in SAM or just completed an update of entity data in SAM. You should also check to see if the entity's record in SAM has expired.

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What is a valid reason for a SAM exception?

The reasons outlined in the FAR are:

1. Purchases that use a government-wide commercial purchase card as both the purchasing and payment mechanism, as opposed to using the purchase card only as a payment method
2. Classified contracts (see FAR 2.101) when registration in the SAM database, or use of SAM data, could compromise the safeguarding of classified information or national security
3. Deployed contracting officers in the course of military operations, including, but no limited to, contingency operations as defined in 10 U.S.C. 101(a)(13) or humanitarian or peacekeeping operations as defined in 10 U.S.C. 2302(7)
4. Contracting Officers in the conduct of emergency operations, such as responses to natural or environmental disasters or national or civil emergencies, e.g., Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 5121)
5. Contracts to support unusual or compelling needs (see 6.302-2)
6. Awards made to foreign entities for work performed outside the United States, and if it is impractical to obtain SAM registration
7. Micro-purchases that do not use the electronic funds transfer (EFT) method for payment and are not required to be reported (see subpart 4.6).

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What if I can’t disclose who the entity is?

Please contact your FPDS Agency System Administration who handles FPDS related issues.

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What is a Unique Entity ID (DUNS) / UEI (DUNS)?

DUNS is short for “Data Universal Numbering System number.” This is a number assigned by Dun and Bradstreet, Inc. (D&B) to identify unique business entities.

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What is a Unique Entity ID (SAM) / UEI (SAM)?

This is an identifier assigned by SAM (short for “System for Award Management”), used to identify unique business entities. Any existing entities which currently have a Unique Entity ID (DUNS)/UEI (DUNS) and are registered in SAM, are automatically assigned a UEI (SAM). New entities who have a UEI (DUNS) but do not have a UEI (SAM) value will be assigned a value upon the first contract creation of FPDS.

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When creating a Delivery\Task order or a BPA call what is the source of the entity/socioeconomic information that populates the fields?

When creating an award such as a Delivery/Task Order or a BPA Call which references an IDV, the entity name and address and the entity's socioeconomic information is propagated from the IDV. The same process of propagating the entity information from an IDV applies to a Blanket Purchase Agreement (BPA) that references a Federal Supply Schedule (FSS).

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I am entering a modification to a Definitive Contract. Where does the entity information for the current modification come? Is it from the base contract or the latest modification?

The entity information for your current modification comes from the base contract UNLESS you had previously entered a modification where the reason for modification is entity-related such as “Entity Address Change,” “Unique Entity ID (DUNS) or Legal Business Name Change – Non-Novation,” “Novation Agreement,” “Rerepresentation,” or “Rerepresentation of Non-Novated Merger/Acquisition.

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My entity has been taken over by another company. How can I change the entity information for my contract?

Please reference FAR 42.12 to determine if this truly is a novation situation. If this is a novation situation and you have executed a modification reflecting the novation then simply report that modification to FPDS and select novation as the reason for modification

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The entity address information has changed. How can I change only the entity address for my contract?

An entity address change would require a modification to the contract. Once executed you would enter the modification information into FPDS using "Entity Address Change" as the reason for modification.

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The Unique Entity ID (DUNS) for my entity has changed but not other entity information and per FAR 42.12 this is not a Novation situation. How do I change just the Unique Entity ID (DUNS)?

A modification to the contract would need to be executed and then reported to FPDS using “Unique Entity ID (DUNS) or Legal Business Name Change – Non-Novation” as a reason for modification.

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What if the entity information is not correct in FPDS?

Entity information in FPDS reflects the entity as it was at the time of the contract award. A contract awarded to an entity ten years ago will reflect the entity socio-economic status as of 10 years ago unless a modification was executed to update this information. If this a new contract, check SAM to ensure if the information is correct.. If this is a Deliver\Task Order or BPA Call the entity information will populate from the vehicle you are ordering against (i.e., the IDV or BPA). If the entity information is not correct in SAM you need to contact the entity and request that they correct their data. If the data is coming from a referenced IDV, you should contact the Contracting Officer for that IDV.

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Two contracts are using the same Unique Entity ID (DUNS) yet the entity information is different. Why?

Entity information in FPDS is based on when the contract was awarded. A contract awarded last year will contain entity information as of last year. The same entity may have updated their information in SAM since that contract award and that updated information will appear on any contracts entered into FPDS.

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Does each modification reflect current SAM information?

No. Entity socio-economic data appears in FPDS as it did at the time of the award. On a Delivery\Task Order, BPA Call or BPA referencing another IDV the entity information pulls from the IDV being referenced and reflects the entity status as of the award of that vehicle. (Entity socio-economic information will only be updated if a modification for re-representation, novation, or a non-novated acquisition\merger is entered)

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I was awarded a contract two months ago and my entity just got a socio-economic certification (Service Disabled Veteran, 8(a),Etc.). Is it okay for me to go back and update the entity information or request that this information be updated so that my agency can receive small business goaling credit for this entity?

No. The entity information in FPDS reflects the entity's status at the time of the award. The contract was awarded when the entity rerepresented (in ORCA or through Section K Representations and Certification) themselves as having certain socio-economic statuses and that is what is required to be reported to FPDS.

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A query I ran shows what I believe to be a large business as small, this must be an error correct?

Not necessarily. Small business determinations are not based on just the entity name. A seemingly large entity may actually be deemed small by the Small Business Administration in certain industrial categories. A large IT company for example, may be considered a small business in clothing manufacture. The size determination is based on the North American Industry Classification System (NAICS) code used for the procurement in question and how an entity represents itself in the Representations and Certifications to the government.

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PBSA

What is PBSA?

Performance-Based Service Acquisition (PBSA), formerly known as Performance-Based Service Contract (PBSC), is defined in FAR 37.601. PBSA applies if the contract:

1. Describes the requirements in terms of results required rather than the methods of performance of the work
2. Uses measurable performance standards (i.e., terms of quality, timeliness, quantity, etc.) and quality assurance surveillance plans (see 46.103(a) and 46.401(a))
3. Specifies procedures for reductions of fee or for reductions to the price of a fixed-price contract when services are not performed or do not meet contract requirements (see 46.407) and
4. Includes performance incentives where appropriate.

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For PBSA to apply what percent of work must meet the PBSA requirements as defined in FAR 37.601?

For FPDS reporting purposes for FY2005 and later a minimum of 50% of the requirements under the procurement action must meet the above FAR standards. For FPDS reporting purposes for FY 2004 and prior, a minimum of 80% of the requirements under the procurement action must meet the FAR standards.

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How do I know if I may have a contract where PBSA applies?

See FAR 37.6.

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ADMINISTRATIVE TRANSFER

What is Administrative Transfer?

Administrative Transfer Action is a reason for modification which is meant to be used when one Department or Agency transfers a contract to another. It is not intended for transfers between offices. Admin Transfer privileges are distributed via the Agency System Administrator.

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What steps are required for the transferring agency?

1. The transferring agency will create a modification and selects Transfer Action as the Reason for Modification
2. The transferring agency will change the contracting office agency ID and contracting office ID to reflect the agency that will be receiving the contract
3. Once the Contract Action Report (CAR) has been approved an e-mail is automatically sent to the transferring agency’s system administrator

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What steps are required for the receiving agency?

1. The receiving agency System Administrator will receive an e-mail notifying them of the transfer
2. The receiving agency can proceed with whatever the next modification is (could be change PIID, could be additional funding, etc.)
3. The first modification after transfer will open almost every field on the contract action report but the data that is transferred with the CAR should not be changed. Only unique agency specific fields (DoD and NASA) not available previously should be completed.

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CHANGE PIID

What is Change PIID?

Change PIID is a reason for modification. It is a new user privilege only supplied to the Department System Administrator. If an agency has created a modification that changes the contract PIID they would use this reason for modification when entering data into FPDS. The change PIID reason for modification allows the user to change the PIID, the PIID agency code or both. Change PIID can only be used once through the duration of the contract.

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What happens when entering a modification where the reason for modification is Change PIID?

1. When Change PIID reason for modification is selected, the PIID or the PIID agency code or both must be changed and the validation rules for change PIID will fire.
2. The following fields are available for editing and at the very least the PIID or the PIID Agency code must be changed:
• PIID Agency code
• PIID
• Modification Number
• Date Signed
• Contracting Officer Agency ID
• Contracting Officer
• Period of Performance Start Date
3. Once Save Draft is selected the user will be unable to change\correct the piid or piid agency code. If a mistake was discovered while still in a draft status the contract action report can be deleted.

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How can I locate an old PIID?

The user cannot search on the OLD PIID. The old PIID will display as “Other Award ID” or “Other IDV ID” on the screen when doing an advanced search.

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REREPRESENTATION

What is Re-representation?

See FAR 19.301.

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What happens in FPDS when reporting an action where the reason for modification is Rerepresentation, Non-novated acquisition and merge, or Novation?

If Rerepresentation or Non-novated acquisition or merger is chosen as the reason for modification then the entity's socio-economic information is refreshed from SAM and the Contracting Officer’s Determination of Size field is opened. A novation assumes the possibility of a rerepresentation and if that is selected as the reason for modification then the entity field is opened for the user to enter the new Unique Entity ID (DUNS) and the CO Size’s determination is opened.

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Do I have to create a modification if the entity's size status has not changed?

No, you would have no changes to the terms and conditions of the contract so a modification would not be necessary and there would be no contract action to report to FPDS.

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If I have a rerepresentation that means I should ask the entity to submit a new subcontracting plan and should be able to change my answer to subcontracting plan in FPDS, correct?

No. The terms and conditions of the contract have not changed as a result of the rerepresentation.

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TREASURY ACCOUNT SYMBOL (TAS)

What is a Treasury Account Symbol (TAS)?

The Federal Funding Accountability and Transparency Act requires agencies to report the Program Source aka Treasury Account Symbol (TAS) for all contract actions involving funding to USASpending.gov. The Treasury Account Symbol is provided to FPDS on a weekly basis by the Department of Treasury see http://www.fms.treas.gov/fastbook/index.html. TAS are validated against the listing provided from the Department of Treasury. The Office of Management and Budget's guidance on reporting FFATA actions defines the TAS format as a two character agency code, four character account code, and the three character sub account code (if applicable).

Per OMB FFATA guidance dated March 6, 2008: Agencies shall immediately develop policies that establish the owner of the TAS at the finance office and instruct all contracting/assistance officers to accept purchase requests (PRs)/notices of awards/applications, only if they contain the predominant TAS applicable to the action clearly identified on the face of that document. In addition, agencies that obtain contract or grant assistance services from another agency or organization shall provide their TAS in compliance with the Transparency Act. The originating TAS must be a part of the funding agency’s interagency agreement or RWA. The subsequent reporting of the action, shall be based on the funding agency’s TAS not that of the contracting or grant-making agency.

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RECOVERY

How do I identify Recovery Act related procurement actions in FPDS?

Users will select the data element, American Recovery and Reinvestment Act, to identify Recovery Act actions.

Prior to June 25, 2016, this data element is required when the Action Obligation amount is either less than or greater than zero dollars.

On or later than June 25, 2016, this data element is optional, regardless of the Action Obligation amount, or if the ‘American Recovery and Reinvestment Act’ is selected as the Initiative.

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FUNDING AGENCY\FUNDING OFFICE

What is a funding agency\funding office?

The funding agency\funding office is the agency\office that has the requirement and provided the funding for that requirement which has now resulted in a contract award.

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Is my finance office the funding agency\office?

No. The agency\office that developed the requirement and is using their money to fund the procurement is the funding agency\office.

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Why won’t FPDS let me fill in the Subcontracting Plan field?

There are certain procurement situations where a subcontracting plan is not required, see FAR 19.704.

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What are the options for Subcontract Plan and what do they mean?

The FPDS specifications are as follows. Any additional questions regarding why something is or is not appropriate for the action you are entering should be researched in the FAR.

1. Plan Not Included – No Subcontracting Possibilities - A Subcontracting Plan was not included in the contract because subcontracting possibilities do not exist (FAR 19.705-2I)
2. Plan Not Required – No Subcontracting Plan was required. (For example, the action did not meet the dollar thresholds in FAR 19.702(a))
3. Plan Required (Pre 2004)
4. Plan Required - Incentive Included – Includes a Subcontracting Plan and also includes additional incentives (FAR 19.702(a), FAR 19.708(c), and DFARS 219.708(c)). This value is end-dated as of May 1, 2015.
5. Plan Required - Incentive Not Included – Includes a Subcontracting Plan, but does not include additional incentives (FAR 19.702(a) and FAR 19.708(c)). This value is end-dated as of May 1, 2015
6. Individual Subcontract Plan – Applies to a specific contract with goals that covers the entire contract period, including option periods (FAR 19.701)
7. Commercial Subcontract Plan – Commercial plan means a subcontracting plan (including goals) that covers the offerer's fiscal year and that applies to the entire production of commercial items sold by either the entire company or a portion thereof (e.g., division, plant, or product line) (FAR 19.701)
8. DOD Comprehensive Subcontract Plan – A subcontracting plan based on a plant, division, or company-wide basis. This value is only valid for DoD. (DFARS 219.702).

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Is there a way for FPDS to track subcontract plan information?

No, the only data FPDS collects is whether or not the action had a subcontract plan. Subcontracting plan details are tracked in the electronic subcontracting system called eSRS.

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Does FPDS interface with eSRS?

Yes. A contract action report that indicates that a subcontracting plan was required is sent to eSRS.

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CONTRACTING OFFICER’S SIZE DETERMINATION

Why can’t I enter/correct the Contracting Officer’s Size Determination for a Delivery Order?

The CO size determination data element on a Delivery\Task Order is populated from the referenced IDV.

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What resources do we have for deciding Contracting Officer’s Size Determination?

The Online Representations and Certifications Application, which allows entities to enter representations and certifications once for use on all federal contracts www.sam.gov

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LEGISLATIVE MANDATES

When should I select the Service Contract Act?

If you are purchasing services, and the value of the contract is > $2,500. (Check FAR 22.1003-3 for exemptions)

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When would I select Materials, Supplies, Articles and Equipment (formerly Walsh-Healy?)

Walsh-Healy applies to contracts that:

1. May exceed $10,000
2. Is performed in the U.S., Puerto Rico, or the U.S. Virgin Islands, AND
3. Is for the manufacture or furnishing of materials, supplies, articles and equipment

Check FAR 22.604-1 for exemptions

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When should I select Construction Wage Rate Requirements (formerly Davis-Bacon?)

If your contract is for construction, alteration of repair and is also over $2,000 then you most likely should select it. (Check FAR 22.402 for more information)

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When should I select Clinger-Cohen?

When you are purchasing Information Technology

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When does the Interagency Contracting Agreement field apply?

If you are buying on behalf of another agency.

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MISC QUESTIONS

What is the Fee for Use of IDV?

It is the fee paid to an IDV awarding agency for placing an order against that IDV.

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What is the Fee for use of Service?

It is the administrative fee established by the awarding agency that will be charged when you place an order against an IDV. It is not charged for Federal Supply Schedules. (FSS)

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What is appropriate for the “Description of Requirements” field?

Concise details regarding the purchase, in plain English. “Stuff” is not appropriate. No need for extreme detail – just a high level overview of the items or services bought in plain English.

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What is the difference between a MOD and a CORRECT?

A Mod is used when there are changes to the contract terms and conditions.A Correct is used to correct typographical errors or other mistakes when entering data into FPDS.

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What is the difference between the North American Industrial Classification System (NAICS) and Product and Service Codes (PSC)? Why does FPDS have both?

The North American Free Trade Agreement (NAFTA) requires the use of NAICS by the Government. The NAICS classifies commercial activity into broad business categories, such as soybean farming, manufacturer, wholesaler, retail, and services. PSCs describe specific products and services which form the basis for national stock numbers. Both fields are required because statute requires some reports to be based on NAICS information, some on PSC information, and some, such as the Competitive Demonstration Program, must use both codes. It also helps narrow a search if we allow users to select what they want from two or three filters.

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What does Place of Performance really mean?

The information is this field should reflect where the items will be produced, manufactured, mined, or grown or where the service will be performed. This field refers to the entity's final manufacturing assembly point, processing plant, construction site, place where a service is performed, location of mines, or where the product is grown.

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Women-Owned Small Business Categories

The following Women-Owned Small Business flags are available in SAM:

• Women-Owned Small Business
• Women-Owned Small Business (WOSB) Joint Venture eligible under the WOSB Program
• Economically Disadvantaged Women-Owned Small Business (EDWOSB) Joint Venture
• SBA-Certified Women-Owned Small Business
• SBA-Certified Economically Disadvantaged Women-Owned Small Business

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Why don’t these categories display on the Contract Action Report screen?

In V1.5, deployed on October 1, 2017, the first three Women-Owned Small Business flags above will appear on the FPDS contract screen, when appropriate, in the Business Category section under Business Types. The last two flags will appear on the FPDS contract screen, when appropriate, in the Business Category section under Certifications.

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Where can I find out more information about the WOSB program?

For more information on the WOSB program please review FAR Subpart 19 or visit the Small Business Administration website: https://www.sba.gov/contracting/government-contracting-programs/women-owned-small-businesses

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