By: Eric Whytsell
The Department of Defense, NASA, and the GSA are proposing to amend the FAR by implementing a process of standardizing the use of Procurement Instrument Identifiers (PIIDs). These identifiers would be unique to each contracting office within each agency, as well as other grant and finance offices throughout the Federal Government. This proposed rule, 78 Fed. Reg. 34020-01, which was introduced on June 6, 2013, seeks to create an environment of “uniformity and consistency of data.” The government hopes this will promote transparency in Federal spending by better allowing participants in the procurement process to be identified.
Currently, various agencies and contracting officers use PIIDs of different lengths and with differing punctuation and spacing. By doing away with this variation, these agencies hope to allow for the tracking of procurement transaction across an electronic database. This is currently impossible given the lack of uniformity among PIIDs. In moving away from paper tracking of transactions, the agencies sponsoring this rule also propose to lessen the waste of time and labor spent gathering procurement data under the current system. Further, paper-free tracking of procurement transactions allows for the elimination of the element of human error. This increased accuracy will also allow for more efficient oversight, as discrepancies are less likely to be the product of tracking errors. Finally, contractors can compare their records with those of the government, leading to increased accountability for both sides.
The proposed new PIID system will involve a combination of thirteen to seventeen letter or numerical characters. It will disallow the use of special characters, including any kind of punctuation or spacing. The first six characters will identify the agency seeking the procurement. Characters seven and eight will be the last two digits of the fiscal year in which the procurement will be awarded. The ninth character will identify the type of procurement, such as blanket purchase agreement, task order, etc. Finally the remaining characters will be assigned by the issuing agency as unique identifiers for the contracting office within that agency.
Those interested in submitting comments on this proposed rule should do so before August 5, 2013. These comments should be addressed in response to FAR case 2012-023 at the address listed here.
This article was drafted by Summer Associate Michael Samuels, with guidance from attorneys Katie Calogero and Eric Whytsell.
© Jackson Kelly 2013