Behind the Music: CCR

By NEIL GORDON

A notice posted in the Federal Register last month provides a unique look at the CCR. (No, not these guys.)

Any company, organization, or individual who wants to do business with Uncle Sam must first register in the Central Contractor Registration (CCR). The CCR is the primary database for collecting information about all federal contractors, grantees, and other federal assistance recipients.

The CCR organizes that information into 260 data fields, many of which have been deemed off-limits to the public as per Exemption 4 of the Freedom of Information Act (FOIA), which protects "trade secrets and commercial or financial information obtained from a person [that is] privileged or confidential." The Federal Register notice lists all 260 data fields and their FOIA status. Non-exempt CCR data (fields 1 – 155 and 157 – 164) can be downloaded as Microsoft Excel-readable "extracts" posted on the Acquisition.gov website. (Warning: these files are more than 100 megabytes in size and might not work in some versions of Excel.)

POGO is most interested in CCR fields 255 through 260: civil, criminal, and administrative "proceedings" contractors and grantees are required to report in the new FAPIIS database. As explained in the Federal Register notice, these data elements are still considered FOIA-exempt even though they are now disclosed on the public FAPIIS site. (Data entered after April 15, 2011 will be posted on the public site; data reported before April 15, 2011 is supposed to be made available through a FOIA request.) Similarly, fields 250-254, covering executive compensation, are also exempt but are now reported, under certain conditions, on USAspending.gov.

We are puzzled by the exemption status of some of the fields. For example, why are address and point of contact information regarding a recipient's parent company considered privileged or confidential? Sadly, this is par for the course for a government that thinks contractors' past performance reviews should also be withheld from the public.

Neil Gordon is a POGO investigator.