Office of Acquisition and Logistics (OAL)
Part M804 - Administration and Information Matters
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|M804.101||Contracting officer’s signature.|
|M804.202-70||Distribution of construction contract files.|
|M804.802-70||Contract files and eCMS.|
|M804.804||Closeout of contract files.|
|M804.804-1||Closeout by the office administering the contract.|
|M804.805||Storage, handling, and disposal of contract files.|
|M804.1003||Establishing line items.|
|M804.1070-1||Line item numbering.|
|M804.1600||Scope of subpart.|
|M804.1602||Identifying the PIID and supplementary PIID numbers.|
- M804-A – Sample Contractor’s Closing Statement
- M804-B – Sample Contractor’s Release of Claims
- M804-C – eCMS Contract File Documentation
Contracts, contract modifications, blanket purchase agreements, task orders and delivery orders may be executed manually or electronically. In the absence of the original contracting officer, another contracting officer with appropriate warrant authority may sign. Always type or stamp the name and title of the contracting officer signing the contract on the document. A digital signature is specific electronic signature technology that allows the recipient to prove the origin of the document and to protect against forgery. Electronic signatures may be used to sign contractual documents if the requirements of the VA Handbook 6510, VA Identity and Access Management, are followed.
Contracting officers may use the clause FAR 52.204-1, Approval of Contract, in each solicitation where approval to award the resulting contract is required above the contracting officer.
The following prescribes the distribution of signed copies of construction contracts:
(a) The original of the performance and payment bonds shall be filed in a secure location in the contracting office. In addition, a copy of the original performance and payment bonds shall be filed under the appropriate tab in the Electronic Contract Management System (eCMS) briefcase.
The process for reporting contract actions to Federal Procurement Data System–Next Generation (FPDS-NG) is incorporated into eCMS. Data in FPDS-NG is stored indefinitely and is electronically retrievable. Therefore, the contracting officer may reference the contract action report approval date in the associated Government contract file instead of including a copy of the electronically submitted contract action report in the file. Such reference satisfies contract file documentation requirements of FAR 4.803(a).
(1) Contracting officers are responsible for reviewing and submitting accurate and complete FPDS-NG information. FPDS-NG reporting is required to complete contract actions in eCMS. Detailed specifications of FPDS-NG data reporting requirements are contained in the FPDS-NG Frequently Asked Questions page.
(2) Contracting officers shall ensure accurate data is entered in FPDS-NG for all contract actions whose estimated dollar value is above the micro-purchase threshold (MPT), including calls and orders awarded under an idefinite delivery vehicle (IDV) (as identified in FAR 4.606(a)(1)(ii)). All modifications to these contract actions must be reported in FPDS-NG, regardless of dollar value. In addition, VA requires FPDS-NG reporting for all calls and orders valued at or below the MPT, that are awarded under an IDV by a contracting officer (CO) or ordering officer (OO). All calls and orders placed by OOs will be reported by the CO responsible for the contract or agreement. VA encourages the use of the FPDS-NG Express Reporting capability, when appropriate.
(3) All acquisition professionals should receive FPDS training. Training may be provided by the FPDS-NG Application Coordinator in accordance with local policy. To ensure the integrity of FPDS-NG information, acquisition professionals must have access to the following materials:
Product and Service Codes Manual; It can be found under the reference section.
NAICS codes; and,
(4) OFPP Memorandum ‘Improving Federal Procurement Data Quality - Guidance for Annual Verification and Validation,’ dated May 31, 2011 requires agencies to certify they have policies, procedures, and internal controls in place to monitor and improve procurement data quality. The annual Verification and Validation (V&V) program was established to comply with Federal mandates and professional knowledge and capabilities of VA personnel involved with entering and reviewing VA Acquisition Data in the FPDS.
(5) The head of the contracting activity (HCA) shall establish procedures for conducting a V&V of FPDS data to ensure the accuracy of that quarter’s procurement data. A sample will be pulled within two weeks after the end of each quarter and will be placed in the FedDataCheck tool. The auditor will use the V&V form in FedDataCheck.
(6) The V&V shall include each of the FPDS data elements identified in the FedDataCheck FPDS V&V Dashboard. For each selected contract action in the sample, the auditor shall compare the data contained within each data element pulled from FPDS with that from the actual contract file. The V&V auditors shall annotate the results and findings during the review of each randomly selected FPDS record utilizing the provided form.
(7) Each sampled FPDS record must be validated against the associated contract file by an individual other than the contracting officer who awarded the contract or the person entering the contract data into FPDS. The reviewer cannot use the information found on the data values tab in eCMS but must use the official contract files found in the briefcase of the eCMS action. Data elements that cannot be validated must be considered incorrect and this includes FPDS record data elements that, while they match the contract file, are determined to be inaccurate.
(8) Each HCA shall ensure that all V&V for their organization for each fiscal year are completed by December 15th of each year. They will ensure that all FPDS record data element found to be inaccurate will be corrected by the contracting office in FPDS.
(9) Monthly, each HCA shall certify acquisition data by verifying and reporting the number of reportable contract actions (base contracts and all modifications) awarded and the number of records reported to FPDS-NG. Any contracts left in draft or error status in FPDS-NG and contracts listed on the eCMS report titled, “Not Final on Awarded Actions” are considered reportable contracts for certification, and a detailed plan, including timeline for completion of those actions, is required. Each HCA shall furnish their certification no later than the fifth workday of each month and report all data as cumulative during the fiscal year. Contact Enterprise Acquisition Systems Service (EAS) (003A2B) with questions or to obtain the required reporting template.
(10) On an annual basis, each HCA shall certify acquisition data by verifying and reporting the number of contract actions (base contracts and all modifications) awarded and the number of records reported to FPDS-NG. Any contracts left in draft or error status in FPDS-NG and contracts listed on the eCMS report titled, “Not Final on Awarded Actions” are considered reportable contracts for certification, and a detailed plan, including timeline for completion of those actions, is required. Each HCA shall furnish their certification annually by December 15 for the previous fiscal year to EAS (003A2B). Contact EAS with questions or to obtain the required reporting template.
(11) Contracting officers shall ensure accurate data is entered in FPDS-NG for all contract actions whose estimated dollar value is above the MPT, including calls and orders awarded under an IDV (as identified in FAR 4.606(a)(1)(ii)). All modifications to these contract actions must be reported in FPDS-NG, regardless of dollar value. In addition, VA requires FPDS-NG reporting for all calls and orders valued at or below the MPT, that are awarded under an IDV by a CO or OO. All calls and orders placed by OOs will be reported by the CO responsible for the contract or agreement. VA encourages the use of the FPDS-NG Express Reporting capability, when appropriate.
(1) Use of the eCMS is mandatory when soliciting for, awarding, or administering contracts so there is a clear record of the Department’s contract actions available for internal and external audits, program reviews, advanced reporting, and other oversight functions. The contract file will be maintained in the contracting office.
(2) Procurement officials shall require submission of all documents electronically from all sources, both internal and external, that are required to be maintained as part of the contract file. When official solicitation or contract documents cannot be uploaded in eCMS due to system limitations contracting officers shall mark and place such documents in a properly marked hard copy contract file. The contracting officer shall prepare a memorandum for the contract file that discloses the location and disposition of the hard copy contract file. The signed memorandum shall be filed under a dedicated eCMS Briefcase Index tab in accordance with HCA procedures. Working papers or working files shall not at any time be comingled or filed with official procurement documents and/or uploaded in eCMS.
(1) Prior to receiving an eCMS account, complete training in the use of eCMS and obtain a production account. eCMS users must remain current in their training, to include initial user training and intermittent training such as major software changes.
(3) Upload to eCMS-Automated Acquisition Management System (AAMS) all documents associated with the action which cannot be generated within eCMS, including a complete copy of the final executed and signed contract, any associated modifications, technical and legal reviews.
(4) Enter all data and documents in accordance with the requirements of FAR 4.803–Contents of Contract Files. Enter all data completely and reliably, as specified in eCMS training with particular attention to the following details:
(iii) Properly name and label all uploaded files/documents to describe those documents. No special characters should be used in the names. Only documents associated with an action are to be placed in its briefcase; do not “Copy” or “Move” briefcases to any subsequent action.
(1) Ensure eCMS contains all documents necessary to support the CO’s decision throughout the acquisition cycle including market research, planning and developing requirements, soliciting and evaluating offers, making awards and notifying unsuccessful offerors, and administering the contract through contract closeout. Include in the appropriate eCMS briefcase, all the required contract file documentation specified in FAR 4.803 – Contents of contract files.
(2) Confirm, prior to signing any action prepared for the CO’s signature by other VA personnel, the contents of the eCMS contract file conform to the requirements of FAR 4.803. Per FAR 1.602, contracting officers are responsible for ensuring performance of all necessary actions for effective contracting, and safeguarding the interests of the United States.
(3) Ensure pre/post-procurement milestones are established in eCMS. The milestones must be appropriate for the complexity of the procurement. Additionally, these milestones must track the trends and show the results of the entire procurement phase and processes such as pre-solicitation, contract award, contract administration and contract closeout for all acquisitions including construction.
(3) Evaluate personnel according to eCMS usage performance standards as outlined in employee performance plans, where applicable, to ensure the Action Briefcase properly documents all contracting officer decisions as required at every stage of the acquisition cycle.
(8) Move files in the Archive Closed Shared Desktop to the ECMS ADMIN NATIONAL DESKTOP (DELETION) Shared Desktop when notified by the Contracting Officer who shall ensure adherence to the provisions of FAR 4.805 - Storage, Handling, and Disposal of Contract Files;
Contracting officers may use locally developed forms or templates containing statements of completion approved by the respective HCA. The form or statement shall be retained in the official contract file. Samples and Templates of various contract closeout documents are provided in Attachments M804-A through M804-C—Attachment M804-A, Sample Contractor’s Closing Statement, Attachment M804-B, Contractor’s Release of Claims, and Attachment M804-C, eCMS Contract File Documentation.
This subpart prescribes policies and procedures for assigning line item numbers and the standard information to be made available for each line item.
(c) The severable or non-severable nature of a requirement influences the contract line item numbering (LIN) structure and must be considered in determining the appropriate use of accounting classifications and their assigned accounting classification reference numbers.
(d) Generally, installation services are severable; the government receives the full benefit of the service each time it is performed. Non-severable deliverables typically have a delivery date for products or a completion date for tasks. Severable services are typically recurring during a specified period. Most Research, Development & Testing requirements are non-severable; they cannot be feasibly subdivided. Thus, the government will receive a benefit only upon delivery or completion of the entire requirement. It is important that financial managers and contracting officers evaluate severability case-by-case for each contract action. Contracting officers should seek legal advice when the severable or non-severable nature of a requirement or LIN is difficult to discern.
(e) The financial management official, in consultation with the contracting officer and requirements official, must decide to use an annual or a multiple year appropriation only after considering the severable or non-severable nature of each LIN and the performance start and end dates. This decision will ensure compliance with the funding rules concerning period of availability, bona fide need, and purpose. Complying with these rules will avoid any violations of the Antideficiency Act. When funding decisions are not straight forward, such as using multiple year appropriations or when annual funding is used to cross fiscal years in accordance with FAR 37.106, contracting officers must document the basis for funding decisions in the contract file.
(f) Obligating annual funding for severable LINs at the end of fiscal year requires extra care to show that decisions made were executed as planned. The contracting officer must document the contract file with evidence that performance or a duty to perform occurred in the fiscal year funds were available and obligated to establish a bona fide need. The requirements official or financial management official must provide the evidence. For example, if FY19 annual funds are obligated on 25 September 2019 for a twelve-month period of performance, the file must show there was a duty to perform or that performance started before 30 September 2019. If the requirements official cannot provide this evidence for the file, then using the FY 19 funds to pay for this service is not proper and the customer will have to provide FY20 funds to pay for the service.
Accounting classification reference number means any combination of a two-position alpha/numeric code used as a method of relating the accounting classification citation to detailed line item information contained in the schedule.
Attachment means any documentation, appended to a contract or incorporated by reference, which does not establish a requirement for deliverables.
Definitized item as used in this subpart, means an item for which a firm price has been established in the basic contract or by modification.
Exhibit means a document, referred to in a contract, which is attached and establishes requirements for deliverables. The term shall not be used to refer to any other kind of attachment to a contract.
Non-severable deliverable as used in this subpart, means a deliverable item that is a single end-product or undertaking, entire in nature that cannot be feasibly subdivided into discrete elements or phases without losing its identity.
Undefinitized item as used in this subpart, means an item for which a price has not been established in the basic contract or by modification.
(b) Single unit price. The item shall have a single unit price or a total price, except when the contract is an indefinite delivery type contract and the price of the order is determined by such factors as the quantity of items ordered (e.g., 10-99 @ $100.00, 100-249 @ $95, 250+ @ $90), the destination, the FOB point, or the type of packaging required.
AAAA through AAAZ then
AABA through AABZ then
* * *
AAZA through AAZZ
(iii) Likewise, use all available alpha characters in the third position before selecting a different character in the second position, and then use all characters in the third position before selecting a different character in the first position. For example:
ABAA through AZZZ then
BAAA through BZZZ then
* * *
ZAAA through ZZZZ
(a) The contracting officer is required to use the contractor’s legal or “doing business as” name and physical address information as recorded in the SAM database at the time of award on contract award documents. The contracting officer must identify and report a unique entity identifier (formerly “Data Universal Number System (DUNS)” number) for the successful offeror on a contract action. The DUNS number reported must identify the successful offeror’s name and address as stated in the offer and resultant contract, and as registered in the System for Award Management database in accordance with the provision at FAR 52.204-7, System for Award Management. The contracting officer must ask the offeror to provide its unique entity identifier number by using either the provision at 52.204-6, Unique Entity Identifier, the provision at FAR 52.204-7, System for Award Management, or the provision at FAR 52.212-1, Instructions to Offerors--Commercial Items.
(f) If the unique entity identifier, CAGE code, contractor name, or physical address on a contract no longer matches the information on the contractor’s record in the SAM database, the contracting officer shall process a novation or change-of-name agreement, or an address change, as appropriate.
(i) The SAM website provides useful documents and on-line training to assist with SAM navigation and data entry. User Guides and Demonstration Videos can be found in the User Help section after clicking the HELP link at the top of the website homepage. The former Central Contractor Registration and Online Representations and Certifications Application data is located in the Entity Management area of SAM which can be accessed by navigating the following path after logging into the SAM website. Select Tab - MYSAM, Tab - Data Access and Tab - Entity Management
For personal identity identification of contractor and subcontractor personnel, follow the procedures contained in VA Directive 0710 titled “Personnel Security and Suitability Program,” to ensure compliance with Homeland Security Presidential Directive-12 (HSPD-12) “Policy for a Common Identification Standard for Federal Employees and Contractors,” Office of Management and Budget Memorandum M-05-24, and Department of Commerce FIPS PUB 201.
This subpart prescribes policies and procedures for assigning Unique Procurement Instrument Identifiers (PIID) to all solicitations, contracts, and related instruments in accordance with FAR 4.16.
(a) FAR 4.605 requires agencies to have a process in place that ensures each PIID used to identify a solicitation or contract action is unique Government-wide and will remain so for at least 20 years from the date of contract award. The PIID is also used to report to the FPDS and other designated support and reporting systems Governmentwide.
(b) FAR 4.1601 identifies new policy for PIID numbering which formerly consisted of alpha characters in the first positions to indicate the agency, followed by alpha-numeric characters (“Activity Address Codes: (AAC)); the 2017 format has been changed by moving the AAC to the beginning 6 positions. This subpart identifies the VA process and format to assign a PIID.
(c) Applicability. This guidance applies to all solicitations, contracts and purchase orders, delivery or task orders, blanket purchase agreements, basic ordering agreements, orders, modifications, and related procurement instruments generated within VA’s eCMS.
(d) No other characters shall be used as a part of the PIID other than as prescribed in this part. If additional identification is needed for internal reasons, it shall be placed on the procurement instrument in such a location as to separate it from the PIID. The PIID will be automatically generated in eCMS during the procurement process.
(a) Elements of PIID numbers. Elements of the PIID shall consist of 13 to 17 alpha and/or numeric characters as described in the paragraphs below. The PIID does not contain spaces or hyphens. The characters shall be positioned as follows:
(2) Positions seven and eight. The seventh and eighth positions are the last two digits of the fiscal year in which the procurement instrument is issued or awarded. This is the date the action is signed, not the effective date, if the effective date is different.
(4) Positions 10 through 13. The tenth thru thirteenth positions are the four-character numeric or alpha-numeric serial number. If the highest number is exceeded after 9999, eCMS will use a five-digit number with the first number being 1 (e.g., 10001). Enter the serial number of the instrument in these positions. Contracting activities shall assign such series of PIID numbers sequentially. The HCA may reserve blocks of numbers or alpha-numeric numbers for use by its various components.
An example of a VA PIID is illustrated in Table A below. The sample PIID 36C10117B0001 identifies an invitation for bid issued by the Department of Veterans Affairs, VA Center for Acquisition Innovation, Washington, D.C. in fiscal year 2017.
|1-6||Agency & Organizational Identifier||36C101|
|9||Type of Procurement Instrument||B|
|10-13||4 Position Serial Number||0001|
Table B: Coding for Types of Procurement Instruments
Basic PIID Numbers (Position Nine)
|A||Blanket Purchase Agreements|
|B||Invitation for bids: Use for invitation for bids as defined in FAR 14.2, including those combined with FAR 12.1, Acquisition of Commercial Items|
|C||Contracts of all types except indefinite delivery contracts (see FAR 16.5)|
|D||Indefinite delivery type contracts (including Federal Supply Schedule, Government-wide acquisition contracts (GWACs), and multiple-agency contracts)|
|E||Reserved by FAR for future federal Government-wide use|
|F||Task or delivery orders or basic purchase agreement calls against indefinite-delivery contracts (including Federal Supply Schedules, Government-wide acquisition contracts, and multi-agency contracts), blanket purchase agreements, or basic ordering agreements. See “N” below for orders issued under procurement instruments designated for internal VA use only|
|G||Basic ordering agreements|
|H||Agreements, including basic agreements and loan agreements. Use for cooperative agreements when a PIID formatted number is assigned, but excluding blanket purchase agreements, basic ordering agreements, and leases. Do not use this code for contracts or agreements with provisions for orders or calls.|
|I||In accordance with FAR 4.1603 do not use this letter|
|J||Reserved for future Federal Governmentwide use.|
|K||FPDS Express Reporting (consolidated multiple action reports) may be used for a vendor when it would be overly burdensome to report each action individually|
|L||Lease Agreements: Use for leasing real property, supplies, or equipment to include enhanced-use leases, out leases, etc., except those under the authority of 38 USC 8153, or those captured in Memorandums of Understanding (MOU), Memorandums of Agreements (MOA), and VA/DOD interagency agreements|
|M||MOU/MOA: Use for all MOUs and MOAs and Interagency Agreements|
|N||Delivery or Task Orders (Internal): Use when placing orders under internal VA IDVs to include VA FSS contracts; BPA against VA FSS contracts; or BOAs, including regional, VISN-wide, or station-level contracts|
|O||In accordance with FAR 4.1603 do not use this letter|
|P||Purchase Orders: Use for purchase orders described in FAR 13. (Assign V if numbering capacity of P is exhausted during a fiscal year)|
|Q||Use for Request for Quote, Request for Information or Sources Sought when placing an announcement in Contract Opportunities for informational purposes (assign “U” if numbering capacity of “Q” is exhausted during fiscal year). Use when the procedures in FAR 13 are followed, including those combined with FAR 12.|
|R||Request for Proposal: Use when the procedures under FAR 15 are followed, including those combined with FAR 12|
|S||Sales Contracts: Use for sale of commodities or services, to include excess and sale of space under 38 USC 8153|
|T||Rehabilitation, and Education Services: Reserved for use by Veterans Benefits Administration contracting activities|
|U||See “Q,” request for quotation|
|V||See “P” purchase orders|
|W||Reserved by FAR for future federal Governmentwide use|
|X||Reserved by FAR for future federal Governmentwide|
|Y||Imprest fund use|
|Z||Reserved by FAR for future federal Government-wide use|
(2) Modifications to Contracts, Agreements, and Orders. Modifications to contracts, agreements, and orders shall be assigned a six position alphanumeric serial number in eCMS. The first position will always be “P” or “A” in accordance with the Federal Acquisition Regulation and the five last positions will always be numeric and numbered sequentially beginning with 00001. (e.g. P00001).
(a) The contracting officer shall use the uniform PIID numbering system prescribed in this subpart. In addition, HCAs shall develop local procedures to assign PIIDs to solicitation and contract instruments when eCMS is not available. When eCMS is operational, any solicitations or contracts assigned PIIDs while eCMS was non-operational shall be uploaded to eCMS.
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