Are you trying to file FBAR or FATCA?  F.8938 for FATCA is to be filed with the 1040 and it has much higher thresholds (yes, plural, because that depends on both the taxpayer's filing status and whether he/she resides overseas) for filing than FinCEN 114 for FBAR, which is only $10k.  Unlike FATCA, FBAR is to be filed separately with FinCEN.  The types of accounts, assets, and level of details reportable on F.8938 and FinCEN 114 are also different even though there are some overlaps.

The issue you have with EIN is separate from FBAR/FATCA.  If your client is not employed by a US employer and has no W-2, you need to indicate in your input for wages that it was a foreign employer and services were not performed while resident in the US.  Sorry I can't be more precise since I don't use PS.