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ARTICLE · 21 MARCH 2011

FAPIIS: An Update On The Integrity Database For Government Contractors

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We last discussed the Federal Awardee Performance and Integrity Information System ("FAPIIS") in June 2010.

United StatesGovernment, Public Sector
Bruce Shirk
Bruce Shirk
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We last discussed the Federal Awardee Performance and Integrity Information System ("FAPIIS") in June 2010. We noted then that, as implemented, the rule gives rise to two questions:

  1. Whether FAPIIS creates a risk of disclosure of source selection sensitive information under FOIA; and
  2. Whether FAPIIS will be used when evaluating a contractor's past performance.

This posting updates our June 2010 discussion and undertakes to answer the above-stated questions in light of regulatory developments since that time.

When Congress directed the establishment of a database containing contractor "integrity" and "performance" information, a central repository for the latter half of that equation already existed in the form of the Past Performance Information and Retrieval System ("PPIRS"), which was established in FY 2002 and was designated as the standard government-wide repository for past performance assessments in July 2009. See GAO, Federal Contractors; Better

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