Change Number: Change 155 GSAM Case 2021-G525
Effective Date: 08/30/2022

Subpart 504.6 - Contract Reporting

504.604 Responsibilities.

In accordance with FAR 4.604, the Senior Procurement Executive (SPE) has implemented the following policies to monitor and ensure the accurate and timely input of data into FPDS. Additional guidance is available on GSA’s Acquisition Portal at

      (a)   Contract writing systems.

(1) The responsibility of the contracting officer to report awards in FPDS per FAR 4.604 may be accomplished by a contract writing system that reports the contract action directly to FPDS.

           (2)  Contract writing systems capable of reporting directly into FPDS shall be configured to report as a condition of making an award.

           (3)  Contract actions reported through contract writing systems shall be routinely examined and compared to data contained in FPDS to ensure that those actions have been reported accurately to FPDS.

      (b)   Quarterly Reviews.

(1)  The HCAs are responsible for the following:

                (i)  Establishing a selection methodology for an appropriate random sample of contract files for review that is representative of their Service's contract actions. The sample does not need to be statistically significant.

                (ii)  Verifying and validating the accuracy of contract action reports (CARs) entered into FPDS through the reviews.

                (iii)  Submitting a certification of the accuracy of the CAR data to the Chief Acquisition Officer (CAO). Certifications are due no later than 30 business days after the end of the quarter.

           (2)  Any data discrepancies identified in the contract file during the verification and validation process shall be corrected.

           (3)  File selection and review may begin immediately after the end of each quarter using the selection methodology determined by the HCA in paragraph (b)(1)(i) of this section.

      (c)   Annual Reviews.

(1) In accordance with FAR 4.604(c), the CAO shall annually sample the GSA FPDS records and provide a list of transactions to each HCA for verification, validation, and certification.

           (2)  The verification and validation shall be conducted by an organization or person that did not award the contracts being reviewed. HCAs may institute any appropriate process that complies with this requirement.

           (3)  The process to verify and validate shall include comparisons of contract file data to FPDS data entries and comparisons of FPDS data to contract writing system data to determine completeness and accuracy, if applicable.

           (4)  HCAs shall provide certifications of the accuracy and validity of their FPDS data to the CAO based on the list of transactions provided to HCAs under paragraph (c)(1) of this section.

           (5)  Certifications to the CAO shall include a description of the means used to verify the accuracy and completeness of the data and a statement that all discrepancies found have been corrected.

504.605 Procedures.

      (a)   Uniform procurement instrument identification. This subpart:

           (1)  Prescribes procedures for identifying contracts, orders, and other procurement instruments regardless of dollar threshold.

           (2)  Applies to all contracting activities, except real property leasing.

      (b)   Transition of procurement instrument identifier (PIID) numbering.

      (c)   Policy.

(1)  Contracting officers shall use the uniform PIID numbering requirements for procurement instruments reported to FPDS.

           (2)  Complete the contract number block provided on the applicable forms. If a space is not reserved for the prescribed number, place the number in the upper right-hand corner of the form.

           (3)  Each contracting office must maintain records to ensure continuity and control of PIID numbering.

      (d)   Activity Address Codes (AACs).

           (1)  AACs are made up of the following:

                (i)  The first two characters of the AAC must be “47” to identify GSA.

                (ii)  The third character must be the service/office code identified as follows:

Service/Office Code

Letter Designation

Office of the Administrator


Office of the Chief Financial Officer


Office of Human Resources Management


Office of Mission Assurance


Office of Small Business Utilization


Office of GSA IT


Civilian Board of Contract Appeals


Office of Administrative Services


Office of Inspector General


Office of General Counsel


Office of Governmentwide Policy


Public Buildings Service


Federal Acquisition Service


Congressional & Intergovernmental Affairs


Office of Communications and Marketing


                (iii)  The remaining characters are determined by each service organization, and can be found on GSA’s Acquisition Portal at

           (2)  Central Service Point (CSP) individuals are responsible for establishing and updating AAC assignments in the Department of Defense Activity Address Directory (DoDAAD). Additional guidance on AAC assignments and updates can be found on GSA’s Acquisition Portal at

504.605-70 Federal Procurement Data System Public–Access to Data.

      (a)   The FPDS database. The General Services Administration awarded a contract for creation and operation of the Federal procurement Data System (FPDS) database. That database includes information reported by departments and agencies as required by FAR subpart 4.6. One of the primary purposes of the FPDS database is to provide information on Government procurement to the public.

      (b)   Fee for direct hook-up. To the extent that a member of the public requests establishment of real-time integration of reporting services to run reports from another application, a one-time charge of $2,500 for the original integration must be paid by the requestor. This one-time charge covers the setup and certification required for an integrator to access the FPDS database and for technical assistance to help integrators use the web services. The fee will be paid to the FPDS contractor and credited to invoices submitted to GSA by the FPDS contractor.

504.606 Reporting Data.

      (a)  Reporting requirements. Detailed specification of FPDS data reporting requirements is contained in the FPDS-NG FAQs document available at Reporting offices are encouraged to use automated information systems for FPDS data reporting, provided that the systems contain all required FPDS data elements via the machine-to-machine process and the automated acquisition system has received the proper certification from the FPDS system manager.

      (b)  The GSA FPDS Sustainability Coding Guidelines found on GSA's Acquisition Portal at must be followed when selecting codes for the following sustainability data elements:

           (1)  Recovered Materials/Sustainability.

           (2)  Use of EPA Designated Products.

      (c)  FPDS reporting for acquisitions supporting customer agencies.

(1)  GSA-funded acquisitions. There are instances where GSA conducts an acquisition in support of a customer agency but also provides the predominance of funding for the contract award. In these instances, GSA’s Activity Address Codes (AACs) must be used for the contracting agency codes (e.g. Contracting Office ID) and funding agency codes (e.g. Funding Office ID) in FPDS. Examples of GSA funded acquisitions may include those made in support of—

                (i) Requisitions. These transactions are transfers of property conducted in accordance with the Federal Property Management Regulation (FPMR) (41 CFR 101-26). Examples of programs that facilitate requisitions from customer agencies include GSA stock supply programs and GSA motor vehicle purchasing. Customer agencies submit requisitions (sometimes referred to as “orders”) to GSA for items under these programs in accordance with the FPMR. GSA then acquires these items from suppliers through contracts or orders in accordance with the FAR and GSAM.

                (ii) Shared Services. Under this model, common administrative services-those activities that are common across all agencies-are conducted by an agency (e.g. shared service provider) with expertise in a particular area to reduce duplication and redundancy. In turn, the customer agency reimburses the shared service provider for its costs. Often, shared service providers must conduct acquisitions in order to provide services to other agencies. Accordingly, only the contract/order awarded by the shared service provider to a contractor is reported in FPDS.

           (2)  Customer-funded acquisitions. There are instances where GSA conducts an acquisition in support of a customer agency but the customer agency provides the predominance of funding for the contract action. In these instances, GSA’s AACs must be used for the contracting agency codes (e.g. Contracting Office ID) but the customer agency's AACs must be used for funding agency codes (e.g. Funding Office ID) in FPDS. Examples of customer-funded acquisitions may include—

                (i) Reimbursable Work Authorizations (RWAs). An RWA is an interagency agreement between GSA and a tenant (e.g. federal agency or non-federal source when authorized by statute) whereby GSA recovers its costs for altering, renovating, repairing, or providing services in GSA-managed space over and above the basic operations financed through rent paid by the tenant.

                (ii) Assisted acquisitions (see definition at FAR 2.101). GSA regularly acts as the servicing agency in this type of interagency acquisition, where it performs acquisition activities on a customer (requesting) agency's behalf, such as awarding and administering a contract, while the requesting agency provides the required funding.

      (d) Inherently Governmental Functions. If the procurement is for services, enter the appropriate indicator in the Inherently Governmental Functions field:

           (1) “Closely Associated” means functions that are closely associated with inherently governmental functions; those contractor duties that could expand to become inherently governmental functions without sufficient management controls or oversight on the part of the Government. Office of Federal Procurement Policy (OFPP) Policy Letter 11–01, Performance of Inherently Governmental and Critical Functions, provides examples of work that is inherently governmental and therefore must be performed by Federal employees and work that is closely associated with inherently governmental functions that may be performed by either Federal employees or contractors.

           (2) “Critical Functions” means functions that are necessary to the agency being able to effectively perform and maintain control of its mission and operations. Typically, critical functions are recurring and long-term in duration.

           (3) “Other Functions” means neither “Closely Associated Functions” nor “Critical Functions.”

           (4) For services that include performing both “Closely Associated” and “Critical Functions,” select “Closely Associated, Critical Functions.”