Procurement Information Circular

February 9, 2012




PURPOSE:  The purpose of this PIC is to consolidate PIC 05-03, 06-08, 06-11, 07-04, and 07-05 which all relate to FPDS-NG reporting.   Revision B adds instruction regarding the OMB guidance on data collection requirements to facilitate the Service Contract Inventory process.


BACKGROUND:  The Federal Procurement Data System – Next Generation (FPDS-NG) is the single official source of procurement data for the Federal Government.  The data in FPDS-NG is used by the public as well as other Government entities, such as Congress.  For example, the Small Business Administration uses the data to produce the annual Small Business Goaling Report which is submitted to Congress; the Office of Management and Budget uses FPDS-NG data to produce the Competition Report; and the Government Accountability Office relies upon FPDS-NG data in the conduct of audits and investigations.   The data are also used by all levels of NASA management in making decisions on new policy requirements. 


Section 743 of Division C of the Fiscal Year (FY) 2010 Consolidated Appropriations Act, Pub. L. 111-117, requires civilian agencies to prepare an annual inventory of their service contracts and to analyze the inventory to determine if the mix of Federal employees and contractors is effective or if rebalancing may be required. 


GUIDANCE:  FAR 4.606, provides guidance on which awards are reportable to FPDS-NG.  Timing for such reporting is stated at FAR 4.604(b)(2), ‘When a contract writing system is integrated with FPDS, the Contract Action Report (CAR) must be confirmed for accuracy prior to release of the contract award.’  FAR 4.604(b)(3) further states, ‘When a contract writing system is not integrated with FPDS, the CAR must be submitted to FPDS within three business days after contract award.’


There are several reference documents which are maintained on the FPDS-NG website.  The URL for this website is:  Click on the ‘Worksite’ tab to find reference documents including the FPDS-NG Data Dictionary and the NASA FPDS Data Dictionary.  The FPDS-NG Users Manual, the manuals on Standard and Adhoc Reports as well as computer based training for new users can be found under the ‘Training’ tab.


Beginning March 1, 2012, a new FPDS coding requirement goes into effect.  Contracting Officers  shall review the OFPP Policy Letter 11-01, Performance of Inherently Governmental and Critical Functions, to become familiar with the categories of work and the distinctions in determining  whether the work to be performed under a contract is “closely associated”, “critical”, or an “other function” using the attached table as a guide but using OFPP Policy Letter 11-01 for further examples. 

Inherently Governmental Test

Inherently Governmental

Federal employees because the work is so intimately related to the public interest

Closely Associated

Close to inherently governmental because of the nature of the function.  If contractors  used to perform this work, agencies must give special management attention to the contractors’ activities to guard against their expansion into inherently governmental functions


·         Federal employees to the extent required by the agency to maintain control over functions that are core to the agency’s mission and operations

·         Federal employees or private sector contractors once the agency has sufficient internal capability to control its mission and operations

Other Functions

Private sector contractors


Beginning March 1, 2012, when a contract is initially awarded, and in each modification thereafter, the CO shall include, as the first words in the “description of requirement” field in FPDS, a code to identify the services provided under the contract.  For services that are-

- predominantly for functions closely associated to inherently governmental ones, enter  the words “Closely Associated.”

- critical functions, enter the words “Critical Functions” in capital letters;

- other functions, enter the words “Other Functions” in capital letters. 


Identifying closely associated and critical functions at the time of award should assist agencies (in the case of closely associated functions) in prioritizing which contracts may require increased management attention and oversight to ensure that mission creep does not result in contractors performing inherently governmental functions and (in the case of critical functions) ensure that the Agency does not lose control of its mission and operations.


NASA users are reminded of the following FPDS-NG requirements:

·         Alpha-numeric modification numbers should not be reported to FPDS-NG

·         Interagency Contracting Authority – This field is to be completed when placing an order against another Agency’s contract

·         The Description of Requirements should state in plain language the work being performed on the contract as a whole and should be repeated on each modification.   R&D awards are required to have a 300-500 word description.   The SAP Requisition Number should not be part of the description.

·         Product/Service Codes (PSC) on orders should directly reflect what’s being purchased on the order.  This may differ from the PSC on the contract that the order is placed against.

·         When  making awards using Department of Defense funds, the following procedures, provided by the Director, Defense Procurement, Acquisition Policy, and Strategic Sourcing should be followed:

o   Complete the FPDS data field entitled ‘Funding Office ID’ with the Department of Defense Automatic Addressing Code (DoDAAC) identified on the requisition (most often on a Military Interdepartmental Purchase Request (MIPR), Department of Defense Form 448) that represents the requisitioner for the transaction.  On a MIPR, this is NOT the Pay Office DoDAAC, nor the Accounting Station DoDAAC identified in blocks 13 and 14 respectively.  The requisitioner’s DoDAAC should be identified in block 8 with the identity of the organization providing the MIPR (note that it is often depicted as the first six charactes of the MIPR number in block 5).  Do not accept the requisition/MIPR if the requisitioner’s DoDAAC is not provided.

o   Complete the FPDS data field entitled “Funding Agency ID” with the code shown on the attached matrix that correctly corresponds to the DoDAAC being reported in the “Funding Office ID” data field.  This code should not be confused with similar codes tha are often seen in block 14 of the MIPR.

Please refer to GIC 07-01 for guidance on reporting Grants and Cooperative Agreements to FPDS-NG.


CANCELLATION:  PIC 09-15A cancelled PICs 05-03, 06-08, 06-11, 07-04 and 07-05.  Rev B does not result in any cancellations.


EFFECTIVE DATE:  This PIC is effective as dated and shall remain in effect until canceled or superseded.


HEADQUARTERS CONTACT:  Beverly Smith, Analysis Division (202)358-0472, email:




Ronald Poussard

Director, Contract Management Division





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