Federal Awardee Performance and Integrity Information System
Contracting officers must review and document FAPIIS information for contracts above the simplified acquisition threshold to ensure only responsible contractors are awarded federal contracts.
Overview
FAR 9.104-6 requires contracting officers to review and consider information in the Federal Awardee Performance and Integrity Information System (FAPIIS) before awarding contracts exceeding the simplified acquisition threshold. FAPIIS consolidates data on contractor performance, integrity, exclusions, and related entities (such as affiliates, immediate owners, subsidiaries, and predecessors). Contracting officers must use this information to inform responsibility determinations, request additional information from offerors if necessary, and document their decision-making process. The regulation also outlines procedures for handling information about subcontractors and mandates proper documentation in the contract file and FAPIIS for nonresponsibility determinations.
Key Rules
- FAPIIS Review Requirement
- Contracting officers must review FAPIIS (including SAM Exclusions and CPARS) before awarding contracts above the simplified acquisition threshold.
- Consideration of Affiliates and Predecessors
- Officers must consider information on immediate owners, subsidiaries, and predecessors of the offeror, as identified in FAPIIS.
- Responsibility Determination
- All relevant FAPIIS information must be weighed, including mitigating factors and the relevance of past actions to current responsibility.
- Handling Subcontractor Information
- Information about subcontractor violations is posted to the prime contractor’s FAPIIS record, and mitigating factors must be considered.
- Request for Additional Information
- If adverse information is found, officers must request additional information from the offeror and notify agency officials if debarment or suspension may be warranted.
- Documentation
- Officers must document how FAPIIS information was used in the contract file and, if a nonresponsibility determination is made, record it in FAPIIS.
Responsibilities
- Contracting Officers: Review FAPIIS, consider all relevant information, request clarifications, notify agency officials if needed, and document decisions.
- Contractors: Ensure FAPIIS records are accurate, respond to requests for additional information, and post mitigating factors if applicable.
- Agencies: Oversee compliance, maintain FAPIIS data integrity, and initiate debarment or suspension actions when appropriate.
Practical Implications
- This section ensures that only responsible contractors receive federal contracts by requiring a thorough review of past performance and integrity data.
- It impacts daily contracting by making FAPIIS review a mandatory step and requiring careful documentation.
- Common pitfalls include failing to review all relevant FAPIIS data, overlooking affiliate/predecessor information, or insufficiently documenting the responsibility determination process.