Part M804 - Administration and Information Matters - Office of Acquisition and Logistics (OAL)
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Office of Acquisition and Logistics (OAL)


Part M804 - Administration and Information Matters

« VAAM Part M803 VAAM Table of Contents VAAM Part M805 »
Subpart M804.1—Contract Execution
M804.101 Contracting officer’s signature.
M804.103 Contract clause.
Subpart M804.2—Contract Distribution
M804.202-70 Distribution of construction contract files.
Subpart M804.6—Contract Reporting
M804.602 General.
M804.604 Responsibilities.
M804.605 Procedures.
M804.606 Reporting data.
M804.606-70 Reporting Procurement Administrative Lead Time (PALT).
Subpart M804.8—Government Contract Files
M804.800 Scope of subpart.
M804.802 Contract files.
M804.804 Closeout of contract files.
M804.804-5 Procedures for closing out contract files.
M804.805 Storage, handling, and disposal of contract files.
Subpart M804.9—Taxpayer Identification Number Information
M804.904 Reporting payment information to the Internal Revenue Service (IRS).
Subpart M804.10—Uniform Use of Line Items
M804.1000 Scope of subpart.
M804.1001 Policy.
M804.1003 Establishing line items.
M804.1003-70 Numbering procedures.
M804.1004 Establishing subline items.
M804.1004-70 Numbering procedures.
M804.1004-71 Contract exhibits and attachments numbering.
Subpart M804-11—System for Award Management
M804.1103 Procedures.
Subpart M804.13—Personal Identity Verification
M804.1301 Policy.
M804.1303 Mandatory clause – FAR 52.204-9, Personal Identity Verification Requirements.
Subpart M804.16—Unique Procurement Instrument Identifiers
M804.1600 Scope of subpart.
M804.1603 Procedures.


  • M804-A – Sample Contractor’s Closing Statement
  • M804-B – Sample Contractor’s Release of Claims
  • M804-C – Sample Contract File Documentation Template
  • M804-D – Supply Chain Master Catalog Line Item Detail Requirements

Subpart M804.1 - Contract execution

M804.101  Contracting officer’s signature.

Contracting Officers may utilize either electronic (digital) or physical (handwritten) signature on contracts, orders, agreements, modifications and supporting documentation. This includes accepting a digital signature(s) from contractors, provided the contracting officer confirms that the signer(s) has authority to bind the contractor. An electronically signed contract action which includes the name of the contracting officer satisfies the typed, stamped, or printed requirement found in FAR 4.101.

M804.103  Contract clause.

HCAs should establish procedures for when the clause FAR 52.204-1, Approval of Contract, is included in solicitations when approval to award the resulting contract is required above the contracting officer.

Subpart M804.2 - Contract Distribution

M804.202-70  Distribution of construction contract files.

(a) In addition to the distribution requirements of (a) In addition to the distribution requirements of FAR 4.201, the contracting officer, as appropriate, should distribute and maintain one executed copy of the documents listed below: FAR 4.201, the contracting officer, as appropriate, should distribute and maintain one executed copy of the documents listed below:

(1) The original of the performance and payment bonds must be filed and secured electronically.

(2) Contracts and modifications must be distributed electronically to the contractor and payee office.

(3) The designated Contracting Officer’s Representative must also receive an electronic copy of the signed contract and modifications.

Subpart M804.6 - Contract Reporting

M804.602  General.

Detailed specifications of Federal Procurement Data System–Next Generation (FPDS-NG) reporting requirements are contained in the Frequently Asked Questions (FAQ) document available at

M804.604  Responsibilities.

(a)(1) HCAs are responsible for performing quarterly verification of FPDS data. The FedDataCheck tool will generate a sample of VA awards for FPDS Verification &Validation (V&V) upon the completion of each quarter. The HCA must certify the contract action reports (CARs) no later than 30 business days after the end of the quarter.

(2) HCAs are responsible for submitting an annual certification that the FPDS data has been reviewed for completeness and accuracy. As stated previously, the FedDataCheck tool will generate a sample of VA awards for FPDS V&V annually. Each HCA must furnish their certification by December 15 for the previous fiscal year to the Enterprise Acquisition System Service (EASS).

(b)(1) Contracting Officers (CO) are responsible for reporting awards, when the award process was conducted using other than micro-purchase procedures and the value is greater than the micro-purchase threshold (MPT).] In addition, VA requires FPDS-NG reporting for all calls and orders valued at or below the MPT, that are awarded under an Indefinite Delivery Vehicle (IDV) by a contract specialist and or ordering officer (OO). Modifications to existing contract awards must also be reported, regardless of dollar amount.

(2) The contracting officer must confirm the CAR prior to release of the contract award and complete the CAR in FPDS within three business days after contract award. CARs in a draft or error status in FPDS are not considered complete.

M804.605  Procedures.

(a) Uniform Procurement Instrument Identifier (PIID) numbering. Contracting officers must use the uniform PIID numbering requirements for procurement instruments reported to FPDS, regardless of dollar threshold. VAAM M804.1603 provides numbering requirements and lists the elements of a VA PIID and Supplemental PIID (SPIID).

(b) Unique entity identifier (UEI). Prior to contract award, the contracting officer must: (1) Verify that the UEI corresponds to the successful offeror’s name and address as listed in the System for Award Management (SAM); and (2) ensure that contract award documents and related financial transaction data record the actual UEI contractor information and NOT “generic” information, to prevent improper payments. The UEI should be verified along with the contractor’s Commercial and Government Entity Code (CAGE) Code listed in SAM.

(c) Office codes. Use the Activity Address Code (AAC), as defined in FAR 2.101, assigned to the issuing contracting office as the contracting office code, and use the AAC assigned to the program and or funding office providing funding for the contract action, as the program and or funding office code.

M804.606  Reporting data.

(a) Contracting officers must choose the correct FPDS format to report the award of a new contract, agreement, or order, valued above the micro-purchase threshold (MPT), regardless of solicitation process used (e.g., Indefinite-Delivery Contract (IDC), purchase order, basic ordering agreement (BOA), blanket purchase agreement (BPA)). Any modification to these contract actions that change previously reported contract action data, regardless of dollar value, must also be reported. Not every data element is addressed here, users should consult the FPDS Data Element Dictionary, located at, for more complete descriptions and examples. This section uses data field names based on what is shown to the user while entering data in FPDS.

(1) FPDS Entry – Contract Identification Information.

(i) Enter the new contract, agreement, or order number in the “Procurement Instrument Identifier” data field (1A).

(ii) If the action is a BPA awarded against a Federal Supply Schedule (FSS), enter the FSS contract number in the “Referenced IDV ID” data field (1C).

(iii) If the action is a BPA call awarded against a BPA, enter the BPA number in the “Referenced IDV ID” data field (1C).

(iv) If the action is a modification, enter the contract, agreement, or order number in the “Procurement Instrument Identifier” data field (1A) and the modification number in the “Modification Number” data field (1B).

(v) If the award is associated with a solicitation, enter the solicitation number in the “Solicitation ID” data field (1E).

(vi) If the award is associated with an initiative identified in FPDS (e.g., American Recovery and Reinvestment Act), chose the appropriate value in the “Treasury Account Symbol Initiative” data field (6SC).

(2) Monthly FPDS Express Reporting. The Ordering Officer (OO) must provide a monthly report to the CO, that includes a list of orders placed, number of actions, the amount obligated/deobligated, the award/order date, source of data, and program office description. When Express Reporting is used, the CO must submit a contract action report (CAR) with the information obtained from the OO’s monthly report. The CAR must be submitted not later than the 10th day of the following month via the contract writing system, using Express Reporting capabilities for consolidated multiple action reports. The CO is responsible for verifying the report of orders placed by the OO to the FPDS entries to ensure accurate reporting into FPDS.

M804.606-70  Reporting Procurement Administrative Lead Time (PALT) data.

(a) PALT is defined as “the time between the date on which an initial solicitation for a contract or order is issued and the date of the award of the contract or order.”

(b) For award of a new contract, purchase order, task and or delivery order, or BPA Call valued above the SAT, contracting officers must include the solicitation issuance date, regardless of whether the new award: Was required to be advertised (i.e., posted on the applicable Governmentwide point-of-entry, etc.); Is an order under a single-award IDC; or, Is an award that was not competed. The following guidance is provided for determining the date on which an initial solicitation is issued:

(1) When issuing a draft solicitation for the purpose of seeking input from interested parties, to assist the Government in developing its final solicitation – the “initial solicitation” date is the date on which the final solicitation seeking offers, bids, or proposals is issued.

(2) An award(s) resulting from unsolicited proposals, the “initial solicitation” date is the date on which the Government notifies the offeror of proposal acceptance.

(3) Orders placed against IDCs, where pricing is based on pre-priced line items included in the IDC, and no elements of the order’s delivery or performance require negotiation, the “initial solicitation” date is the date of the award of the order. NOTE: When the CO requests a proposal, that may lead to the negotiation of cost or technical elements of the proposed order, the “initial solicitation” date is the date the request was forwarded to the contractor.

(4) An award of a contract under a Broad Agency Announcement (BAA), the “initial solicitation” date is the date when a final combined synopsis and or solicitation is issued, except:

(i) For two-step BAAs, including white paper submissions for review, selection, and subsequent request for full proposals, the “initial solicitation” date is the date when the Government signs the proposal request.

(ii) Under BAAs with calls, the “initial solicitation” date is the date when the individual call is issued.

(iii) For open BAAs, when white papers and or proposals are accepted for review over an extended period (typically open for a year or longer), the “initial solicitation” date is either the date when the Government signs a proposal request (white papers) or the date on which the proposal is submitted, whichever is earlier.

Subpart M804.8 - Government Contract Files

M804.800  Scope of subpart.

This subpart proposes a contract file format standard for all contracts that exceed the MPT. This subpart may also be applied to purchases at or below the MPT. This standard is to ensure that the documentation in the file complies with FAR 4.801(b)(1) and FAR 4.802(c) requirements.

M804.802  Contract files.

(a)(1) All official procurement files must contain complete documentation to constitute a complete history of the acquisition (including payment responsibilities) and any subsequent actions taken by the contracting office. Contract files must be maintained electronically, unless otherwise determined in writing, by the Senior Procurement Executive (SPE) to be prohibitively burdensome. All files must be maintained in accordance with the processes and procedures applicable to the contract writing system used (i.e., Electronic Contract Management System (e-CMS), Automated Acquisition Management Solution (AAMS), Integrated Financial and Acquisition Management System (iFAMs), etc.). Actions placed by an Ordering Officer (OO) must be contained in an electronic file. The Contracting Officer should complete and include the applicable contract file checklist.

(b) Contracting officer responsibilities include:

(1) Placing all applicable documentation included at FAR 4.802 and 4.803 in the contract file and organize the file in the format as set out in each individual contracting activity's contract file standard.

(2) Individuals (e.g., Contracting Officer and or Contract Specialist) creating documents relating to the contract must include those documents in the official contract file on behalf of the contracting officer. Other members of the acquisition team may be responsible for the maintenance and archival of any delegated responsibilities (e.g., contract administration and delegated contract administration function) according to prescribed contracting activity policies and procedures.

(i) Include an index or checklist identifying the location of any documentation contained in the contract file when such identification is not already prescribed by policy. Contract writing systems that include an electronic file index or checklist can be used if available. Attachment M804-C, Sample Contract File Documentation Template is provided for reference.

(ii) Identify in a clear and logical manner, within the contract file, any documentation maintained in another location.

(iii) Comply with applicable file and document naming convention and or nomenclature requirements.

(3) When responsibility for a contract transfer from one contracting officer to another contracting officer (e.g., employee departure, transfer of assignments, or redelegation of contract administration authority (intraoffice or interoffice)) occurs–

(i) The successor contracting officer must review the files being transferred. The purpose of the review is to identify any issues with the contract file (e.g., missing, or incomplete documentation or information).

(ii) The successor contracting officer must attempt to resolve any issues identified during their review of the transferred files. The successor contracting officer should write a memo-to-file that documents any issues with the contract file that were not able to be resolved as part of the transfer.

(c) HCA responsibilities. HCAs consistent with their delegated authorities may develop standard operating procedures (at their discretion) that discuss, at a minimum, the following:

(i) The different types of files identified in FAR 4.801(c) along with any other files that are to be established (e.g., unsolicited proposals).

(ii) The location where file documentation is to be stored (e.g., an electronic contract filing system, another official system of record, or some type of combination thereof). If file documentation must be stored in different locations, the rationale for the need (e.g., separation of classified and unclassified documentation) and medium (e.g., paper) to be used.

(iii) The use of a checklist or index that includes the citation of the authority for retaining a document.

(iv) The filing and document convention/nomenclature to be used.

(v) The content, access, and other applicable requirements for contracting officer representative (COR) contract files; and

(vi) The internal controls (e.g., quarterly review by the contracting activity) to be used for ensuring compliance with FAR and VAAM requirements.

M804.804  Closeout of contract files.

(a) A contract should not be closed out until all terms and conditions of the contract have been satisfied by the contractor and the Government. Additionally, contract actions in active litigation or appeal; and or terminated contract actions, cannot be closed out until all pending actions have been completed. In situations that are beyond the contracting officer's control, where necessary administrative actions are required by others (e.g., cognizant audit agency, contractor, etc.), the contracting officer should maintain close liaison with these entities to ensure that the necessary actions are not unduly delayed and are completed.

M804.804-5  Procedures for closing out contract files.

(a) Contracting Officer Responsibilities Upon Evidence of Physical Completion. Upon receipt of evidence of physical completion of a contract, the contracting officer must enter the status of “physically complete” (or similar) into the contract writing system applicable to the contract.

(1) For closeout of a firm fixed price contract or order with a total contract value under the SAT, contracting officers must confirm:

(i) All deliverables have been received, inspected, accepted or services performed, and the final invoice paid; and

(ii) There are no complexities involved with the contract or order. Complexities, for the purpose of this section, are defined as: rights in data, property, patent, trademark or copyright, disputes, terminations, equitable adjustments, or any potential legal concern.

(2) Contracts for supplies are considered automatically closed once all deliverables have been received, inspected, accepted, and the final invoice paid.

(3) Contracts for services are considered automatically closed when all deliverables have been received, the final invoice paid and there has been no activity (no invoices, vendor communication, etc.) for six months.

(b) Contracting Officer Responsibilities To Reconcile Financial Balances of Physically Completed Contracts.

(1) Upon receipt of evidence of physical completion of a contract (including those contracts using simplified acquisition procedures, the contracting officer must determine if any outstanding financial balance(s) exist.

(2) Any outstanding balances (e.g., through discussing final billings with contractors, descoping, deobligating funds, cancelling the contract in whole or in part, or terminating the contract in whole or in part, as applicable). The contracting officer must then take the necessary corrective action(s) to resolve such financial balances.

(3) A Contract Completion Statement may be utilized to satisfy the requirements of FAR 4.804-5(b). See Attachment M804-A, Sample Contractor’s Closing Statement; or a Contractor’s Release of Claims, Attachment M804-B, Contractor’s Release of Claims. The form or statement must be retained in the official contract file.

(c) Contracting Officers are required to report contract closeouts to FPDS.

(1) Physically complete firm-fixed price contracts or orders under the SAT, with no complexities, do not require a closeout modification, but must be reported to FPDS using the closeout button functionality. If for some reason a contract closeout modification was issued under these physically complete firm fixed price contracts or orders under the SAT, with no complexities, then the contracting officer must report the modification to FPDS using ‘Closeout’ under the ‘Reason for Modification’ drop-down instead of using the closeout button.

(2) Contract modifications issued to close out the contract must be reported to FPDS using ‘Closeout’ under the ‘Reason for Modification’ drop-down (NOTE: Closeout modifications may also serve multiple purposes such as deobligation of final funds, finalization of indirect cost and or overhead rates, transfer of property, settlement of disputes, etc., but the ‘Closeout’ reason for modification should be used). Closeout modifications are intended to represent the last activity under a contract and are not easily corrected in FPDS, therefore contracting officers must take extra care when reporting these actions and must thoroughly review the contract action report(s) before approving them.

(d) Contracting Officers must approve FPDS contract action reports for closeout modifications at the same time the modification is signed.

M804.805  Storage, handling, and disposal of contract files.

(a) Contracts and order files will be retained and disposed of as authorized by appropriate agency record control schedules. In no case may the files be destroyed before the timeframes specified in the applicable FAR subpart.

Subpart M804.9 - Taxpayer Identification Number Information

M804.1000  Reporting payment information to the IRS.

The VA Office of Financial Services reports to IRS on payments made for services performed and or supplies received, pursuant to 26 U.S.C. 6041 and 6041A and implemented in 26 CFR. To assist the Office of Financial Services in reporting to the IRS, all obligating documents sent to Finance (e.g., purchase, delivery, or task orders; contracts; or certified invoices) must indicate the contractor's organizational structure (e.g., corporation, or partnership) and taxpayer identification number (TIN).

Subpart M804.10 - Uniform Use of Line Items

M804.1000  Scope of subpart.

The subpart identifies agency-specific requirements associated with the capabilities of the contract writing system(s) and proposes best practices and examples that can be used when establishing line items.

M804.1001  Policy.

The requirement for the uniform use of line items apply to solicitations, contracts, orders, and agreements that include pre-priced supplies or services, including amendments, modifications and change orders to such documents. Pursuant to FAR 4.1001, line items “are established to define deliverables or organize information about deliverables. Each line item describes characteristics for the item purchased, e.g., pricing, delivery, and funding information.”

M804.1003  Establishing line items.

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. Severable services are typically recurring during a specified period. Non-severable deliverables typically have a delivery date for products or a completion date for tasks. It is important that financial managers and contracting officers evaluate severability on a case-by-case for each contract action. Consideration must also be given to the chosen unit of measure, on the administration, funding, and payment method (FAR Part 37.106). Contracting officers should seek legal advice when the severable or non-severable nature of a requirement or LIN is difficult to discern and document the basis for funding decisions in the contract file. Contracting officers must always establish a separate line item when options are contemplated.

(a)(1) Solicitations and contracts must establish line items that comply with FAR Part 4.1003, and may include any of the following characteristics:

(i) Are “separately identifiable.” For purchase of supplies, any item that has its own identification (e.g., national stock number (NSN), item description, manufacturer’s part number) is considered separately identifiable and should be listed as a separate line item in the Schedule. For service contracts, “separately identifiable” means that there is “no more than one statement of work or performance work statement.”

(ii) Have a single unit price or total price (except when the items or services are acquired on a cost-reimbursement contract). Cost type line items must not include unit prices, however, must contain the appropriate elements in accordance with FAR Part 16. Not separately priced (undefinitized) line items must be so labeled.

(iii) Have a single accounting classification citation. (NOTE: A line item may have more than one accounting classification citation; also, the same accounting citation can apply to more than one line item).

(iv) Have a separate delivery schedule or destination. When deliverables identified in the contract Schedule do not have separate delivery schedules, periods or places of performance or other separately-identifiable elements as stated in FAR 4.1003, COs are not required to establish a line item for such a deliverable. COs should use their discretion to determine whether to establish separate line items for all or some of the award deliverables.

(A) Supplies: Quantities must match the actual count of the supplies to be delivered, e. g., if more than one delivery is expected, the quantity cannot be “1.”

(B) Services: Quantities must match the frequency with which performance will be reviewed, and on fixed-price line items, payment made. For example, a contract with a twelve-month period of performance should have a quantity and unit of measure suited to how the contract will be managed. If the intent is to review, accept, and pay for the services monthly, then the quantity should be 12, with a unit of measure such as “Months” or “Lots.” If the intent is to review, accept, and pay for the services quarterly, then the quantity should be 4, with a unit of measure such as “Lot.” If the quantity used is 1, then no payment for delivery can occur until the end of the period of performance. Services with tangible deliveries, such as repairs, should be structured like supply line items.

(v) Have single or multiple contract pricing types (e.g., a hybrid contract where deliverables have different contract types, e.g., Cost-Plus-Fixed-Fee (CPFF) and Firm-Fixed-Price (FFP)).

(vi) FAR Part 4.1005-1(a)(1) permits agencies to establish Line item or subline items in accordance with agency procedures. Organizations that place orders from the Supply Chain Master Catalog (SCMC), must include the elements included in Attachment M804-D, Supply Chain Master Catalog Line Item Detail Requirements.

M804.1003-70  Numbering procedures.

All line items are created and modified at the requisition stage, which then carry forward to the solicitation/award stage. Since the funds are committed under the requisition line items, the requesting office must coordinate with the CO while they are first creating the requisition to ensure the line items are properly established for the solicitation/award that will eventually be created from that requisition. (NOTE: the FAR allows for the same accounting code to be entered on multiple line items. When this happens, the requesting office will add the same accounting code for each line item and ensure the amount of funding matches each line item total). This structure will carry forward from the requisition to the solicitation/award stage.

If the CO determines the appropriate line item structure for the solicitation/award is different than the requisition line items, COs must coordinate the necessary changes with the requesting office to modify the requisition line item(s); this must be done prior to creating the solicitation/award.

(a) Line items must consist of either four numeric digits, 0001 through 9999, or five numeric digits, 00001 through 99999, as permissible by the applicable contract writing system (i.e., Electronic Contract Management System (e-CMS) – Automated Acquisition Management Solution (AAMS), Integrated Financial and Acquisition Management System (iFAMs), etc.). Each line item must have a unique number that cannot be used for another line item within the contract. The item numbers must be sequential but need not be consecutive. The contract line item number must be the same as the solicitation line item number, unless there is a valid reason to use different numbers. For example, FAR 4.1007 and the clause at FAR 52.204-22 allow offerors to propose an alternative line item structure when such changes provide economic or administrative advantages to the Government. Once a line item number has been assigned, it must not be assigned to another, different, contract line item in the same contract.

(b) Line items indicating options (e.g., option years, ordering periods), should relate to the applicable existing line item. For example, the first numerical digit of an option line item would be the number of the option itself (for example “1” for year 1, “2” for year 2 and so on); the remaining digits would be the same as the line item it is referring to. The below example illustrates the line item numbering for options, using five digit numbering.

Line item Description
00001 Base Period
00002 Base Period - Maintenance and Repairs
00003 Base Period - Construction
01001 Option Year 1 - Period
01002 Option Year 1 - Maintenance and Repairs
01003 Option Year 1 - Construction
02001 Option Year 2 - Period
02002 Option Year 2 - Maintenance and Repairs
02003 Option Year 2 - Construction

M804.1004  Establishing subline items.

FAR 4.1001 (b) allows agencies to subdivide a line item into separate subline items to ease administration. However, all funding must be provided at the line item level.

M804.1004-70  Subline Numbering procedures.

(a) Deliverable subline items. May be established for related items that are similar, except for minor variances. Variations include, but are not limited to size or color, accounting classification, delivery dates, period, or place of performance; packaging and handling, and items separately identified at the time of shipment or performance. Use alpha characters only for deliverable subline items. Defaults start with AA, running through ZZ. For example, if the contract line item number is 0001, the first three subline items would be 0001AA, 0001AB, and 0001AC. Use all 24 available alpha characters in the second position before selecting a different alpha character for the first position. For example, AA, AB, AC, through AZ before beginning BA, BB, and BC. Do not use the letters I or O as alpha characters.

(b) Informational subline items. May be established to identify information that relates directly to the line item (e.g., parts of an assembly or parts of a kit); or to identify multiple accounting classification citations assigned to a single contract line item. Use alpha-numeric or numeric characters, or a combination thereof, for informational subline items only. Defaults may start with A1 or 01. For example, if the contract line item number is 0001, the subline item numbering could start with either 000101 or 0001A1. Informational subline items must be included within the line item description, not the quantity or price sections.

(c) If a contract line item involves ancillary functions, like packaging and handling, transportation, payment of state or local taxes, or use of reusable containers, and these functions are normally performed by the contractor and the contractor is normally entitled to reimbursement for performing these functions, do not establish a separate subline item solely to account for these functions. However, do identify the functions in the contract schedule. If an offeror separately prices these functions, the contracting officer may establish separate subline items for the functions; however, the separate subline items must conform to the requirements of this section.

(d) Subline items structured to identify different accounting classifications for identical items and or delivery schedule, must be established for each subline item, not the contract line item.

M804.1004-71  Contract exhibits and attachments numbering.

(a) Use of exhibits.

(1) Identify exhibits individually.

(2) Each exhibit must apply to only one contract line item or subline item.

(3) More than one exhibit may apply to a single contract line item.

(i) Separately priced. When data are separately priced, enter the price in contract schedule.

(ii) Not separately priced. Include prices in a priced contract line item or subline item.

(4) The contracting officer may append attachments to exhibits if the attachment does not identify a deliverable requirement that has not been established by a contract line item or subline item or exhibit line or item.

(b) Numbering exhibits and attachments.

(1) The criteria for establishing exhibit line items are the same as those for establishing subline items.

(2) Use alpha or numeric characters to identify exhibits. The alpha characters must be either single or double capital letters. Do not use the letters I or O.

(3) Once an identifier has been assigned to an exhibit, do not use it on another exhibit in the same contract.

(4) If the exhibit has more than one page, cite the procurement instrument identification number, exhibit identifier, and applicable contract line or subline item number on each page.

(5) Use numbers to identify attachments.

(c) Numbering exhibit line items.

(1) The first position or the first and second position contain the exhibit identifier.

(2) The third and fourth positions contain the alpha or numeric character serial numbers assigned to the line item when using a double letter exhibit identifier. The second, third and fourth positions contain the alpha or numeric character serial numbers assigned to the line item when using a double letter exhibit identifier.

(3) Exhibit line item numbers must be sequential within the exhibit.

(4) Examples.

(i) Two-position serial number for double letter exhibit identifier.

Cumulative No. of Line Items Serial Number Sequence
1-33 01 thru 09, then 0A thru 0Z, then
34-67; et. al. 10 thru 19, then 1A thru 1Z, et. al.

(ii) Three-position numbers.

Cumulative No. of Line Items Serial Number Sequence
1-33 001 thru 009, then 00A thru 00Z, then
34-67; et. al. 010 thru 019, then 01A thru 01Z, et. al.

Subpart M804.11 - System for Award Management

M804.1103-70  Procedures.

Contracting officers must use the SAM database as the primary source of contractor information for contract award and administration.

(a) Unless one of the exceptions to registration in SAM applies (see FAR 4.1102), the contracting officer must not award a contract to a prospective contractor who is not registered in SAM. If no exceptions are applicable, and the need of the requiring activity allows for a delay in award, see FAR 4.1103(b).

(b) When deciding to exercise an option, or at any other time before issuing a modification other than a unilateral modification making an administrative change, ensure that–

(1) The contractor’s record is active in the SAM database; and

(2) The contractor’s UEI, CAGE code, name, and physical address are accurately reflected in the contract document.

(c) At any time, if the UEI, 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 must process a novation or change-of-name agreement, or an address change, as appropriate.

Subpart M804.13 - Personal Identity Verification

M804.1301  Policy.

(a) Homeland Security Presidential Directive-12 (HSPD-12), entitled “Policy for a Common Identification Standard for Federal Employees and Contractors,” was issued to enhance security and reduce identity fraud related to contractor physical access to Federally-controlled facilities and or logical access to Federally-controlled information systems.

(b) The requirements of HSPD-12 apply to all solicitations, contracts, or orders for services, including services incidental to supply contracts and orders where the contractor will require routine, recurring, or continuous physical access to VA controlled facilities and or logical access to VA controlled information systems.

M804.1303  Mandatory clause - FAR 52.204-9, Personal Identity Verification Requirements.

Insert the clause at 52.204-9, Personal Identity Verification Requirements, in solicitations and contracts when it is determined that contractor (including subcontractor) employees will require staff-like access to VA Sensitive but Unclassified (SBU) information (electronic or paper-based), VA facilities or information systems or assets that process, store, or contain SBU, wherever the location, and irrespective of ownership of the information system or infrastructure in use.

Subpart M804.16 - Uniform Procurement Instrument Identifiers

M804.1600  Scope of subpart.

This subpart prescribes procedures, guidance, and instruction for assigning Unique Procurement Instrument Identifiers (PIID) in all solicitations, contracts, and related instruments.

M804.1603  Procedures.

(a) Elements of a PIID. . VA issued PIIDs may be up to seventeen characters in length. Use only alpha-numeric characters, as prescribed in FAR 4.1603 and this subpart. Do not use the letter I or O in any part of the PIID, or special characters (spaces, dashes, or hyphens). NOTE: The prevailing guidance for creating a PIID within VA is provided in the contract writing system specific to the applicable organization. The characters must be positioned as follows:

(1) Positions one through six. The first six characters of the PIID represent the office issuing the award; this code is known as the activity address code (AAC). This code will be reported in FPDS in the contracting agency office ID field and is also the issuing office information that appears on the contract award document. Every VA AAC begins with the Department identifier – 36, followed by a letter representing the component. The remaining three characters of the AAC are left to the components discretion.

(2) Positions seven and eight. A two-digit numeric code that is the last two digits of the fiscal year in which the PIID is awarded. The fiscal year is the fiscal year during which the contract action is awarded and or issued (i.e., the date signed), it does not the represent effective date. A contract signed on September 30, 2022 (FY22), for example, with an effective date of October 4, 2022 (FY23), would use ‘22’ in the PIID because the award was signed in FY22.

(3) Position nine. A one-digit alphabetic code, in Table B below, identifies the type of procurement instrument (e.g., agreement, sealed bidding, contract, etc.).

(4) Positions ten through seventeen. Components may use the remaining characters of the PIID in whatever way they choose, however, the PIID in its entirety must be exactly 17 characters long and must be unique

(5) Illustration of PIID. An example of a PIID is illustrated in Table A below. The PIID 36C10122B00011234 identifies an invitation for bid issued by the Department of Veterans Affairs, VA Center for Acquisition Innovation, Washington, D.C. in fiscal year 2022.

Table A: Elements of a PIID

Position Identification Code
1-6 Agency & Organizational Identifier 36C101
7-8 Fiscal Year 22
9 Type of Procurement Instrument B
10-13 4 Position Serial Number 0001
14-17 As determined by the Component 1234

Table B: Coding for Types of Procurement Instruments (Position Nine)

Instrument Letter
Blanket Purchase Agreements A
Invitation for Bid B
Contracts of all types except indefinite delivery contracts (see FAR 16.5) C
Indefinite delivery type contracts (including Federal Supply Schedule, Government-wide acquisition contracts (GWACs), and multiple-agency contracts) D
Reserved by FAR for future federal Government-wide use E
Task or delivery orders or calls under – 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 F
Basic ordering agreements G
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. H
In accordance with FAR 4.1603 do not use this letter I
Reserved for future Federal Governmentwide use. J
FPDS Express Reporting (consolidated multiple action reports) may be used for a vendor when it would be overly burdensome to report each action individually K
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 and or DoD interagency agreements L
MOU/MOA: Use for all MOUs and MOAs and Interagency Agreements M
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 N
In accordance with FAR 4.1603 do not use this letter O
Purchase Orders: Use for purchase orders described in FAR 13. (Assign V if numbering capacity of P is exhausted during a fiscal year) P
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). Q
Request for Proposal: Use when the procedures under FAR 15 are followed, including those combined with FAR 12. R
Sales Contracts: Use for sale of commodities or services, to include excess and sale of space under 38 USC 8153. S
Rehabilitation, and Education Services: Reserved for use by Veterans Benefits Administration contracting activities. T
See “Q,” request for quotation. U
See “P” purchase orders. V
Reserved by FAR for future federal Governmentwide use. W
Reserved by FAR for future federal Governmentwide. X
Imprest fund use. X
Reserved by FAR for future federal Government-wide use. Z

(b) Supplementary Procurement Instrument Identifiers (SPIIDs). SPIIDs must be used in conjunction with the PIID to identify the following:

(1) Amendments to Solicitations. Amendments must be assigned a four position numeric serial number, always sequentially, beginning with 0001.

(2) Modifications to Contracts, Agreements, BPA Calls, and Orders. Modifications to all awards (including contracts, agreements, BPA Calls, purchase orders, and task oand or delivery orders) must be sequentially with a six-position alphanumeric serial number beginning with either A00001 (modifications issued by other than the procuring office) or P00001 (modifications issued by the procuring office).

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