Procurement Information Circular

July 2, 2007



PURPOSE:  To provide guidance on entering rerepresentation data into the Federal Procurement Data System (FPDS-NG).


BACKGROUND:  Federal Acquisition Circular (FAC) 2005-18, effective June 30, 2007, established a new requirement for small businesses to rerepresent their size status under the circumstances described in paragraph (b) of the clause at FAR 52.219-28, Post-Award Small Business Program Rerepresentation.  If a contractor indicates that its size status has changed, FAR 4.602(f) now requires the contracting officer to enter the revised size status in FPDS-NG.  After such a rerepresentation, an agency may not take credit for subsequent obligations under the contract against the agency’s small business prime contracting goal achievements.


A modification to FPDS-NG is currently in process to allow contracting officers to enter size status changes without corrupting past entries.  If a contracting officer changes a contractor’s size status in FPDS-NG before this system modification is implemented, the contractor’s size status will be changed retroactively to the date of contact award, and agency small business goal achievements will be lost.  The FPDS-NG modification will ensure that achievements prior to the rerepresentation are preserved, but will not permit small business credit for obligations after the size status change is entered.  


GUIDANCE:  If a contracting officer receives a notification of a size status change under the FAR revisions in FAC 2005-18, do not enter the size change in FPDS-NG as required by FAR 4.602(f) until the FPDS-NG system modification has been implemented.  Since such size changes must be entered in FPDS-NG upon the system modification, Center procurement offices should establish a mechanism to capture any size status change representations received while the FPDS-NG modification is pending to ensure that the data will be subsequently entered (e.g., a centralized log of contractor name, contract number, date of reprepresentation, and the applicable size standard information). 


EFFECTIVE DATE:  This PIC is effective as dated and shall remain in effect until the Office of Procurement advises that the FPDS-NG system change discussed above has been implemented.   


HEADQUARTERS CONTACTS:  For small business policy issues:  Jeff Lupis, Contract Management Division, (202) 358-4773, email:; for FPDS-NG issues:  Beverly Smith, Analysis Division, (202) 358-0472, email:



James Balinskas

Director, Contract Management Division



  PIC List