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Federal Awardee Performance & Integrity Information System (FAPIIS) Overview J. Lisa Romney Defense Procurement & Acquisition Policy.
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Federal Awardee Performance & Integrity Information System (FAPIIS) OverviewJ. Lisa RomneyDefense Procurement & Acquisition Policy
NDAA, Section 872 required development of a ‘database’ on potential awardees for data to support award decisions valued greater than the simplified acquisition threshold Government contracting / grants officials report Terminations for Default (contracts) Terminations for Cause (commercial contracts) Terminations for Material Failure to Comply (grants) Defective Pricing determinations (contracts) Non-responsibility determinations (contracts) Recipient Not-Qualified determinations (grants) Government suspension / debarment officials report Administrative Agreements (in lieu of actual debarment / suspension, action does not prohibit other awards) Vendor has the opportunity to provide comments on posted items Collect information about criminal / civil / and administrative proceedings on vendors for which there has been a finding of fault Information available for 5 years from the date of action FAPIIS Overview
Regulation Changes • FAR Case 2008-027 final rule, effective April 22, 2010: • Established the FAPIIS database • Contracting officers report non-responsibility determinations to FAPIIS • Contracting officers place new clause 52.209-7 (Information Regarding Responsibility Matters) in new contracts above $500K • Vendors report data regarding criminal/civil/administrative proceedings to CCR that will be shared with FAPIIS • Contracting officers must review FAPIIS for any new contract award above the simplified acquisition threshold as part of his/her responsibility determination (FAR 9.104-6) • FAR Cases 2008-016 final rule, effective October 29, 2010, contracting officers report: • Terminations for Default (partial or complete) • Terminations for Cause (partial or complete) • Defective Pricing determinations • OMB has also issued proposed guidance (February 18, 2010) to amend CFR Title 2 to require grants officers report: • Terminations for Material Failure to Comply • Recipient Not Qualified determinations
FAPIIS • In spring 2009, determination was made by the Acquisition Committee for eGovernment (ACE) to leverage the capabilities of CPARS, CCR, and PPIRS to satisfy the 872 requirements • FAPIIS input module on CPARS collects items listed from contracting and grants officers and debarment/suspension officials • Collects basic identification information and provides capability to upload an attachment • Pre-populates from FPDS and CCR when possible • CCR collects the information regarding criminal / civil / administrative proceedings during vendor registration / renewal • FAPIIS search module on PPIRS provides central access to the collected items from • FAPIIS input module on CPARS • CCR criminal/civil/administrative proceedings data • Existing debarments and suspensions in EPLS • Existing past performance evaluations in PPIRS
Data Elements Collected for Government-posted Items Data elements to enable searches and reports (required unless otherwise identified): Record Type (T4D, Non-responsibility, Admin Agreement, etc.) * Date of record/action (when the T4D was signed) * Date / Time Stamp of Posting (New Module will generate) * DUNS number * CAGE code (Optional) Vendor name and address (could pull from CCR or D&B based on DUNS) * Doing Business As (DBA) (Optional) Product Service Code (Mandatory for Contracts only) NAICS (Mandatory for Contracts only) Catalog of Federal Domestic Assistance (CFDA) (Mandatory for grants actions) Solicitation / Funding Opportunity (announcement) number (Mandatory for non-responsibility, not-qualified determinations; Optional otherwise) Contract or Grant Award ID Number (Mandatory for terminations; Optional otherwise) Contract or Grant Referenced Award ID Number (Optional) – e.g. GWAC, FSS, IDV, etc. Government reporting agency and office codes * Government reporting official name *, address *, phone *, email * Ability to upload actual record as a .PDF along with above data (5MB size limit)* Government reporting of suspensions and debarments follow same procedures as today Government reporting of performance assessment reports follow same procedures as today * Mandatory Field
Implementation • Version 1 deployed March 2010 • FAPIIS input module of CPARS – ability to collect all of the contracting / grants officer required postings (e.g., T4D, Non-Responsibility Determinations) • CCR – collect the criminal / civil / administrative proceeding information • FAPIIS search module of PPIRS – ability to access above items, PPIRS, and EPLS • Version 2 deployed October 2010 • FAPIIS included ability to collect administrative agreement information from suspension / debarment officials • Publicly accessible version deployed April 15, 2011 • Provides access to FAPIIS data submitted on/after April 15th • Provides consolidated list of all government-submitted reports • Does not provide links to past performance reports
Future Enhancements • New government report for Determination of Untimely Payments to Subcontractors (Small Business Jobs Act) – pending FAR changes • New government report for Determination by the Secretary of Defense of Contractor Fault (National Defense Authorization Act for FY2011) – pending DFARS changes • Improved search capabilities
Entering a Record • Select Record Type • Click “Enter a Record” 3. Enter DUNS 4. Enter Contract Award ID 5. Click Continue
Entering a Record • Information can be: • Populated from FPDS • Populated from CCR (Awardee Information Only) • Entered Manually
Populated from User Profile Entering a Record Save as Draft = You can make changes later using To-Do List Save and Mark for Release = Available in PPIRS for contractor comments and source selection retrieval
Completing a Record IMPORTANT!! • 30 Days to complete FAPIIS record once started in the system • E-mail reminders sent weekly • Records NOT COMPLETED within 30 days are automatically DELETED!
Modifying a Completed Record • Click Modify a Completed Record 2. Click on Document number to modify
Modifying a Completed Record • Make Changes • Click Save Data
Each registrant is asked ‘gateway’ questions to determine if they are required to provide Criminal / Civil / Administrative Proceedings data
If the registrant is required to provide Criminal / Civil / Administrative Proceedings data – they are first asked to provide contact information for the person at the registrant’s organization that can be contacted for further information about the proceedings that are posted
Registrant then provides the details of the particular proceedings to their record Proceedings entered will show in the registrant’s record in a list
