Understanding Generic UEIs and FPDS Reporting in Government Contracting

The use of generic Unique Entity Identifiers (UEIs) in federal procurement is strictly limited to specific circumstances when reporting contract award data to the Federal Procurement Data System (FPDS). It’s crucial to understand that generic UEIs and their associated CAGE codes should only be used for FPDS reporting and never on contractual documents. Employing generic codes in actual contract actions obscures the vendor’s true identity, hindering accurate electronic processing of invoices, receiving reports, and payments, and potentially leading to misdirected payments.

Federal Acquisition Regulation (FAR) Subpart 4.18 mandates that every contractor be identified by their actual CAGE code on contract actions, with no exceptions. Generic UEIs are solely for reporting specific consolidated actions in FPDS where vendor-specific UEIs are not available or practical.

Methods of Reporting to FPDS

There are primarily three methods for reporting contract actions to FPDS: Individual Contract Action Reports (CARs), Multiple CARs, and Express Reporting.

Individual Contract Action Report (CAR)

This is the standard method, requiring one CAR per contract action. An individual CAR is mandatory for various award types, regardless of value in some cases, and when exceeding the micro-purchase threshold (MPT) in others.

Mandatory CARs for all values include:

Indefinite-delivery contracts
Blanket purchase agreements (BPAs)
Basic ordering agreements
Basic agreements (with value and potential obligations greater than $0)
Task and delivery orders and calls under any agreement or indefinite-delivery contract
Modifications to any contract, agreement, order, or call where a CAR was required for the base award.

Mandatory CARs for awards exceeding the Micro-Purchase Threshold (MPT) when not using micro-purchase procedures:

Purchase orders
Definitive contracts

While not mandatory for micro-purchases below the MPT (currently $10,000, but subject to change – as of the original document), reporting is encouraged as a best practice, especially if not using a Governmentwide commercial purchase card (GPC) or Standard Form 44. For contingency-related purchase orders or definitive contracts, individual reports are required above $25,000, not the standard MPT.

Alt text: Sample Standard Form 1449, a purchase order form used in government contracting, highlighting key sections for contract details.

Multiple CARs

Multiple CARs are necessary when a contract or order is anticipated to involve both foreign and U.S. funding. This determination is made at the time of award. Specific transaction identification numbers are used for reporting multiple CARs in these situations:

Transaction Type	Transaction Number
No multiple CARs	0
Foreign Military Sales (FMS)	14
Non-FMS	16

When reporting modifications, it’s crucial to include the transaction number from the initial base award to properly link the reports. Multiple CARs should be based on FMS and non-FMS funding sources, not contract pricing arrangements.

Express Reporting (Consolidated Reporting)

Express reporting allows for consolidated reporting of multiple contract actions, submitted at least monthly. This method is suitable for situations where individual CAR reporting is overly burdensome due to high volume or remote operations.

Permitted uses for express reporting include:

Multiple actions against a single contract or agreement with high monthly volume (e.g., Defense Commissary Agency orders, housing maintenance).
Actions from locations away from the contracting office (e.g., ships at sea, contingency operations).
Multiple delivery orders using the GPC under Federal Supply Schedules, GWACs, BPAs, BOAs, and other indefinite-delivery contracts.
Energy-related supplies and services by the Defense Logistics Agency (DLA) Energy.
Orders under communications service agreements for local dial tone services.

When using express reports for overseas actions or GPC-based consolidated delivery orders where contract/agreement identification is not feasible, the appropriate generic UEI should be used. Express reports require summing all actions and obligations in relevant data fields and must be submitted at least monthly. Contracting officers must maintain a log of individual actions summarized in express reports for audit purposes, including essential details like PIID, IDV PIID (if applicable), award date, obligation amount, vendor name, and UEI (if known).

Actions Not Reported to FPDS

Certain contract actions are exempt from FPDS reporting, in addition to those listed in FAR 4.606(c). These include:

Orders placed by ordering officers against IDVs awarded by:
- USTRANSCOM for decentralized transportation services (USTRANSCOM reports these).
- DLA Energy for energy-related supplies/services using defense-wide working capital funds (DLA Energy reports these).
Classified contracts, agreements, or orders.

Specific Instructions for Entering Data in FPDS

Contracting officers must use the correct FPDS format (e.g., purchase order, BOA, BPA) for reporting new awards. FPDS has different sections for data entry, and while many fields are self-explanatory, specific instructions are provided for key sections. Consult the FPDS User Manual and Data Element Dictionary for comprehensive details.

FPDS Entry – Document Information Section

Procurement Instrument Identifier: Enter the new contract, agreement, or order number. New awards are Modification 0 in FPDS.
Referenced IDV ID: For BPAs against Federal Supply Schedules, delivery orders, or BPA calls, enter the relevant contract, BOA, or BPA number here.
Modification Number: For modifications, enter the modification number.
Transaction Number: For multiple reports, enter the appropriate transaction number (0, 14, or 16).
Solicitation ID: If associated with a solicitation, enter the solicitation number.
Treasury Account Symbol Initiative: Choose the appropriate value if the award is linked to a specific initiative (e.g., American Recovery and Reinvestment Act).

FPDS Entry – Treasury Account Symbol (TAS) Data Fields

While TAS data fields are no longer mandatory (as of July 2016), understanding them is important for corrections on previous reports. The TAS, provided by the requiring organization, represents the funding source. For foreign government funding not under the Foreign Military Financing Program, specific TAS codes are used based on the nature of the requirement (Operations & Maintenance, Procurement, or R&D).

FPDS Entry – Dates Section

Date Signed: Date the contracting officer signed or awarded the contract action.
Effective Date: Date the period of performance begins. Use authorization date if authorization preceded the signed contract.
Completion Date: Latest performance/delivery date of all exercised line items. Update upon modifications extending this date.
Estimated Ultimate Completion Date: Latest performance/delivery date of all line items, including unexercised options. Update upon modifications extending this date.
Last Date to Order: For IDCs, BOAs, and BPAs, the last date for contractors to accept orders. Update upon modifications.
Solicitation Date: Generally the date of bid invitation, quotation request, or proposal request. Specific rules apply for orders under pre-priced line items, Broad Agency Announcements (BAAs), unsolicited proposals, and orders under indefinite-delivery contracts.

FPDS Entry – Amounts Section

Use a minus (-) sign for net deobligations.
Base and Exercised Options Value: Total value of all exercised line items. Updated on modifications. Report net change in “Current” field for modifications.
Base and All Options Value: Total potential value, including unexercised options. Updated on modifications. Report net change in “Current” field for modifications. For IDVs, this is “Base and All Options Value (Total Contract Value).” For multiple award IDCs, this is the maximum for that specific contract.
Action Obligation: Total obligated funds. Report net change in “Current” field for modifications.
Total Estimated Order Value: For new IDC awards, the total estimated value of all anticipated orders, often matching “Base and All Options Value” for DoD.

FPDS Entry – Purchaser Information Section

Contracting Office ID: Contracting office’s DoD Activity Address Code (DoDAAC).
Funding Office ID: Requiring office’s DoDAAC (if DoD), or Funding Office ID from interagency agreement (if non-DoD).
Foreign Funding: Indicate if the action includes Foreign Military Sales (FMS) funding.

FPDS Entry – Contractor Information Section

Unique Entity Identifier: Vendor’s UEI. Used to pull registration data from SAM.
SAM Exception: Choose if a SAM exception applies to the procurement.

FPDS Entry – Contract Data Section

Type of Contract: Choose the pricing type applicable to the predominant amount. Populates automatically for modifications.
Inherently Governmental Functions: Indicate if services involve inherently governmental, closely associated, critical, or other functions.
Multiyear Contract: “Yes” if a multiyear contract per FAR 17.1.
Major Program: Full program name, not acronym, if applicable. Mandatory for multi-agency contracts for ICD representation.
National Interest Action: Select if related to a specific National Interest Action (e.g., Hurricane Sandy, Operation Enduring Freedom).
Type of IDC: For indefinite-delivery contracts, choose Indefinite Quantity, Requirements, or Definite Quantity.
Multiple or Single Award IDV: Select “Multiple Award” for contracts awarded under multiple-award solicitations, BPAs against Federal Supply Schedules, or other IDIQs requiring competition among vendors.
Program Acronym: For IDVs allowing orders from other offices, enter the program acronym, with specific prefixes for FSSI, MMAC, SMAC, MBPA, and AGYV vehicles.
Cost or Pricing Data: Indicate if certified cost and pricing data were obtained, waived, or not required.
Purchase Card as Payment Method: “Yes” if GPC was used for payment or purchase and payment.
Undefinitized Action: Indicate “Letter Contract” or “Other Undefinitized Action” if applicable.
Performance Based Service Acquisition: “Yes” if performance-based service acquisition procedures were used.
Contingency Humanitarian Peacekeeping Operation: Select “Contingency” or “Humanitarian” if applicable.
Cost Accounting Standards Clause: Indicate if CAS clauses apply or a waiver was approved.
Consolidated Contract: Indicate if requirements are consolidated, bundled, or not consolidated, and if written determinations are in place.
Number of Actions: Enter “1” unless using Express Reporting.

FPDS Entry – Legislative Mandates Section

Clinger-Cohen Act, Labor Standards, Materials, Supplies, Articles, and Equipment, Construction Wage Rate Requirements: “Yes” if applicable to any line items.
Interagency Contracting Authority: Indicate Economy Act, other authority, or not applicable. Specify “Other Statutory Authority” if selected.
Additional Reporting: Select applicable contractor reporting requirements (Service Contract Inventory, Employment Eligibility Verification).

FPDS Entry – Principal Place of Performance Section

Supplies: Predominant manufacturing location or inventory origin. Not the government delivery location. If unknown, use contractor’s SAM-registered physical address.
Services: Predominant service performance location. For transportation, use destination location. For multiple destinations, use predominant delivery location.
U.S. Place of Performance: Enter zip code + 4 for city and state population. Use nearest “+4” extension if exact extension is unavailable.

FPDS Entry – Contract Marketing Data Section (IDVs Only)

Website URL: Website for ordering information (optional but recommended for multi-agency contracts).
Who Can Use: Agencies allowed to place orders. Choose “Only My Agency” if applicable.
Email Contact: Contracting officer’s email for ordering questions.
Individual Order / Call Limit: Maximum order value.
Ordering Procedure: Brief ordering instructions (optional if website URL is provided).
Fee Charged to Ordering Agency: Fee for ordering through the vehicle (percentage, fixed amount, or “no fee”).

FPDS Entry – Product or Service Information Section

Product or service code (PSC): Code representing the predominant supplies or services.
Principal NAICS code: NAICS code representing the predominant industry. Use NAICS from solicitation provisions if specified.
Contract bundling: Indicate Bundled, Substantially Bundled, Bundled under exception, or Not Bundled requirements.
DoD Acquisition Program: Centralized Unique Program Identification (CUPID) code if applicable, or codes for specific programs like PBL, BRAC, environmental, SOFA.
Country of Product or Service Origin: Country code for product manufacturing or service performance.
Place of Manufacture: Indicate “Not a Manufactured End Product,” “Manufactured Outside the U.S. – Use Outside the U.S.,” or specific categories for supplies used within the U.S. (Manufactured in U.S., Trade Agreements, or Buy American Act exceptions).
Domestic or Foreign Entity: Indicate contractor ownership.
GFE/GFP Provided Under This Action: Indicate if Government Furnished Property is included. Maintain initial award value for modifications unless modification adds GFP.
Description of requirement: Short, plain English description of the procurement, avoiding acronyms and jargon. Include “831 Authority” if applicable per DFARS 234.005-1. For modifications, describe the procurement, not the modification type.
Recovered materials/sustainability: Choose the option reflecting sustainability requirements incorporated (FAR 52.223-4, energy efficient, biobased, environmentally preferable, combinations, or “No clauses included and no sustainability included”).

Alt text: Screenshot of a spreadsheet listing Product Service Codes (PSC) from FPDS.gov, used for classifying government purchases by product or service type.

FPDS Entry – Competition Information Section

Solicitation procedures: Select from Simplified Acquisition, Only One Source Solicited, Negotiated Proposal/Quote, Sealed Bid, Two Step, Architect-Engineer, Basic Research, Alternative Sources, or Subject to Multiple Award Fair Opportunity.
Extent Competed: Select from Competed under SAP, Full and Open Competition (F&OC), F&OC after Exclusion of Sources, Not Available for Competition, Not Competed under SAP, or Not Competed. Extent competed for modifications/orders pulls from the basic contract.
Type of Set-Aside: Choose applicable set-aside if the action is a result of a set-aside or sole source under FAR Part 19.
SBIR/STTR: Complete if the action is from a Small Business Innovative Research (SBIR) or Small Technology Transfer Research (STTR) program.
Other than Full and Open Competition: Select justification for non-competitive procedures, referencing FAR Part 6 authority. For SAP, use “SAP Non-Competition,” “Authorized by Statute,” or “Authorized for Resale.”
Fair Opportunity/Limited Sources: Basis for limited competition on orders against multiple-award contracts (Urgency, Only One Source, Follow-On, Minimum Guarantee, Other Statutory Authority, Fair Opportunity Given, Competitive Set-Aside, Sole Source).
Commercial Product or Commercial Service Acquisition Procedures: Indicate if commercial procedures were used for commercial items, supplies/services per FAR 12.102(f), services per FAR 12.102(g), or not used.
Simplified Procedures for Certain Commercial Products or Commercial Services: Indicate if FAR Subpart 13.5 procedures were used.
A-76 Action: Indicate if the action resulted from an A-76/FAIR Act competitive sourcing process.
Local Area Set Aside: Indicate if the action resulted from a local area set-aside per FAR 26.202.
FedBizOpps: “Yes” if award > $25,000 and subject to FAR 5.2 synopsis requirements. “No” if > $25,000 but exception applied. “Not Applicable” if ≤ $25,000.
Number of Offers: Number of offers received. Number of offers for orders pulls from the original contract.

FPDS Entry – Preference Programs / Other Data Section

Contracting Officer’s Business Size Selection: Choose “Small Business” or “Other than Small Business” based on NAICS code, size standard, and contractor certifications. “Other than Small Business” if contractor hasn’t certified. Small Business selection enables socio-economic information from SAM.
Subcontracting Plan: Select subcontracting plan requirement and type (Plan Not Required, Plan Not Included, Individual, Commercial, DoD Comprehensive).

Reporting Modifications to FPDS

Modifications to previously reported contracts, agreements, and orders must be reported to FPDS if they involve any obligation or deobligation amount or change any reported data field.

Choose the “Reason for Modification” that best represents the modification’s purpose. “Novation,” “Vendor UEI Change,” or “Vendor Address Change” take precedence over other reasons for relevant modifications.
Do not use “Close Out” unless the modification actually closes out the award.
DoD offices should not use “Transfer Action” unless transferring to a non-DoD contracting office.
Modifications for novations, vendor UEI changes, and vendor address changes have specific “Reason for Modification” values and require updating the UEI in FPDS.
Modifications for re-representation use “Re-representation” or “Re-representation of Non-Novated Merger/Acquisition.”
Modifications with “Termination for Default” or “Termination for Cause” require reporting to FAPIIS.

Reporting Awards Where GPC is Both Purchase and Payment Method

Do not report open-market GPC purchases below the micro-purchase threshold.
GPC purchases under federal schedules, agreements, or contracts must be reported regardless of value. Report monthly, with individual reports for purchases > $25,000. For purchases < $25,000, options include individual reports, consolidated express reports referencing contracts/BPAs, or consolidated express reports using generic UEIs for “GPC Consolidated Reporting” or “GPC Foreign Contractor Consolidated Reporting.” Generic UEI reporting requires “Other than Small Business” size selection.
FedMall orders are not separately reported to FPDS.

Using Generic UEIs

Generic UEIs are restricted to FPDS reporting under FAR 4.605(c) or for GPC consolidated reporting. Using generic UEIs may hinder downstream reporting (e.g., CPARS, subcontract reporting). Use of generic UEIs should be rare and necessary.

List of Generic UEIs and Corresponding CAGE Codes:

Generic UEI	Description	CAGE Code
LX9KAH68DKV5	Student Workers in Laboratories	35HL9
LN9PU5M2YZN5	Miscellaneous Foreign Awardees	35KC0
L2UVLEUTJU39	Spouses of Service Personnel	3JDV7
KBD2CJ5JXJV5	Navy Vessel Purchases In Foreign Ports	35KD3
JKRMS84PMND5	Foreign Utility Consolidated Reporting	3JDX5
KA5HQCLKUVW1	Domestic Awardees (Undisclosed)	3JEH0
NN2NGPDNCK23	Foreign Awardees (Undisclosed)	3JEV3
R5NWZ87HPLX4	GPC Consolidated Reporting (Domestic)	3JDW4
U9X7H1UVY6U5	GPC Foreign Contractor Consolidated Reporting	3JDV9

Contract Action Report Status

The “Status” field indicates if an award is open or “Closed.” Blank status means “open.” “Closed” indicates completed closeout activities per FAR 4.804.

Status changes to “Closed” via:

Modification with “Closeout” as Reason for Modification (rare).
User with “Closeout” privileges marking award as closed (rare in DoD).
Agency system sending a “Close” notice via web services.

“Closed” status applies to the contract/order and all modifications. Closing orders under IDCs/agreements does not close the IDCs/agreements. Once “Closed,” status changes require FPDS help desk assistance.

This comprehensive guide provides essential information for accurately reporting contract actions in FPDS, particularly regarding the limited and specific use of generic UEIs. Adhering to these guidelines ensures data integrity and compliance in federal procurement reporting.