Agencies have two years to implement a new standard approach to identifying contract awards and other procurement actions.
The Federal Acquisition Regulations Council issued a final rule Monday detailing the timeframe, by Oct. 1, 2017, and steps agencies must take to begin using the Procurement Instrument Identification (PIID) numbering system. The PIID only is for new contracting actions after the effective date.
The FAR Council issued a proposed rule June 2013 as part of its effort to implement the Government Accountability and Transparency (GAT) Board’s recommendations from December 2011. Among the GAT Board’s recommendations was for the government to develop a universal identification number for contracts, loans and grants.
The PIID will require agencies to use a combination of 13 to 17 alpha and/or numeric characters sequenced to convey certain information. The first six numbers should be used for the Activity Address Codes (AACs), which are a unique identifier for contracting offices and other offices. The next two numbers are for the fiscal year of award or action, and the ninth place should be an agencywide standard for the type of contract or vehicle, such as blanket purchase agreement or task order, the agency is using.
The remaining numbers can be used to supplement the PIID for things such as amendments or contract modifications.
“Agencies may choose a minimum of four characters up to a maximum of eight characters to be used, but the same number of characters must be used agency-wide. If a number less than the maximum is used, do not use leading or trailing zeroes to make it equal the maximum in any system or data transmission,” the rule stated. “An agency may reserve blocks of numbers or alpha-numeric numbers for use by its various components.”
No special characters such as hyphens or dashes are allowed.
The first nine numbers are key to this unique identifier. The council stated in the final rule that the AAC is a distinct six-position code consisting of a combination of alpha and/or numeric characters assigned to identify specific agency offices, units, activities or organizations by the General Services Administration for civilian agencies and by the Department of Defense for defense agencies.
“Agencies shall have in place a process that ensures that each PIID used to identify a solicitation or contract action is unique governmentwide, and will remain so for at least 20 years from the date of contract award,” the rule stated. “The PIID shall be used to identify all solicitation and contract actions. The PIID shall also be used to identify solicitation and contract actions in designated support and reporting systems (e.g., Federal Procurement Data System, System for Award Management), in accordance with regulations, applicable authorities, and agency policies and procedures.)”
In the meantime, the council wants agencies to maintain its current PIID format that is in GSA’s Integrated Award Environment program registry.
“The 2013 PIID format consisted of alpha characters in the first positions to indicate the agency, followed by alpha-numeric characters,” the rule stated. “The 2017 format instead has the AAC in the beginning 6 positions.”
The council received only nine comments on the proposed rule.
One comment asked about contract systems that mirror the government’s award numbering system and there will be a cost to the vendor for the update.
“If a contractor chose to structure their contract management system to mirror an agency’s contract writing system, then they may find it necessary to modify their system capabilities to match the new contract identification requirements,” the council said.
The Office of Federal Procurement Policy (OFPP) will monitor agency progress in implementing this rule to determine if it needs to be changed or tweaked.
Consistent and accurate procurement data has long been a problem across the government. There have been several attempts to fix the situation, but few have made a big difference.
The GAT Board’s recommendations, and now the FAR Council’s efforts, coincide with new requirements in the DATA Act.
Congress passed and President Barack Obama signed the Digital Accountability and Transparency Act (DATA Act) into law in May as a part of a major new push to improve data standards.