Does the Fiscal Year of the PIIN Matter?

A BPA was awarded in September with a FY15 PIIN, but performance starts Oct 01 (FY16). I was told that I should have a FY16 PIIN; however the FY16 PIIN is not available. Other suggestion was to start the contract in FY15 so there wouldn't be questions/problems about my PIIN and POP not matching.

***This was a follow on BPA competed. It was awarded/signed by the Gov't prior to the start date so the vendor could be prepared to perform - base access, etc.*****

Is there something I am missing? It seems like the issue of the concern is with September awards with October start dates.

Thanks for your help.

If performance started in FY15 and if FY15 funds were used, then the FY15 PIIN is correct. If, however, the actual period of performance of the award started 1 Oct 15 and if FY16 funds were used, then I would say a FY16 PIIN should have been used. Were FY16 single year funds used to fund the award or where they multi-year funds that were effective in FY15?

There were no funds used to award the BPA. Each customer will use their funds when they place an order and will use their FY16 funds. I hope that helps. Thank you.

For DoD personnel, DFARS 204-7003( a )(2) states "Positions 7 through 8. The seventh and eighth positions are the last two digits of the fiscal year in which the procurement instrument is issued or awarded.". [emphasis added]

Jamaal thanks. That is what I read as well. So does it matter of the POP if it is next FY?

Assuming the primary purpose for having a Universal PIIN system is for things such as standardized administration, data gathering, and reporting, I personally do not think the PoP matters. If it does, surely, someone here will straighten it out.

Jamaal, thanks. Let's see if anyone else has anything else to add.

I think it is pretty clear that the 7th and 8th positions of the PIIN represent the year the contract was awarded, not the year performance begins -- that's the way I have always looked at it.

But I wonder -- if someone does award a contract in SEP 2015 (FY2015) with performance beginning in OCT 2015 (FY2016), and uses the contract clause at FAR 52.232-18, Availability of Funds, do all agencies use a FY2015 PIIN? Are there any agencies who would use a FY2016 PIIN?

My agency isn't funded by annual appropriations, so we don't have this scenario.

FAR 4.1603, "Unique Procurement Instrument Identifiers," subparagraph (a)(2), states:

Positions 7 through 8. 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.

Emphasis added.

It seems clear to me that the year in the PIID (aka PIIN) is not the year in which performance begins or ends or the year for which funds were appropriated. It is exactly what the FAR says it is: "the date the action is signed." Having said that, who knows what agencies actually do?

Thanks Vern and Ji...we are thinking the same way.

It was recommended that I change my period of performance to match the FY so there won't be problems or questions. There was no policy behind it...the request came because the person had a question about how is it possible to have a FY15 PIIN for a FY16 POP. Guess they didn't like my answer.

Thanks you everyone!