Proposed Amendment to FAR Part 4 Would Require Government-Wide Standardization of Unique Procurement Instrument Identifiers (PIID)

Recently the Civilian Agency Acquisition Council (CAAC) and the Defense Acquisition Regulations Council (DARC) proposed an amendment to FAR Part 4 which would require all federal agencies to standardize the use of unique Procurement Instrument Identifiers (PIID).


The current FAR Part 4 standardizes the use of PIIDs within the Federal Data Procurement System (FDPS), but does not apply to other databases containing federal contract reporting data. The proposed amendment is primarily a response to public complaints regarding the inefficiency, duplication, error, mismanagement, and confusion created by the conflicting contract reporting standards of various federal agencies. The standardization required in the proposed amendment would help bring FAR Part 4 into compliance with reporting requirements established in both the Federal Funding Accountability Act (FFATA) and the American Recovery and Reinvestment Act (ARRA), and would inevitably lead to increased governmental transparency and ease of access to federal contract information.

If the amendment is adopted, FAR Part 4.1601 will require all federal agencies to submit PIID information to the General Services Administration's Integrated Acquisition Environment Program Office, which is charged with maintaining a registry of all agency-unique identification schemes. Each PIID would consist of a unique combination of alpha characters to indicate the agency, followed by alpha-numeric characters designating specific agency-related internal classifications. The alphanumeric identifier would be effective for no fewer than 20 years after a contract award and would be used in each solicitation, contract, agreement, amendment, modification and order, thus providing uniformity and reducing opportunities for duplication and confusion.

The text of the proposed rule can be found here. The public is invited to submit written comments to the proposed rule for consideration in its final formulation on or before October 18, 2010 via the Federal Rulemaking Portal (keyword: FAR Case 2009-023). For more information, please contact Mark Blando at[email protected] or (612) 236-0160.