Federal Awardee Performance and Integrity Information (FAPIIS)

The Federal Awardee Performance and Integrity Information System (FAPIIS) is a publicly accessible federal database that consolidates records about contractors' past performance problems, integrity issues, and legal findings. Contracting officers are required to review FAPIIS before making a responsibility determination on any contract award exceeding the simplified acquisition threshold. A significant FAPIIS record can -- and frequently does -- result in a contractor being found non-responsible and excluded from award.

What is FAPIIS?

FAPIIS was established by Section 872 of the Duncan Hunter National Defense Authorization Act for Fiscal Year 2009 (Public Law 110-417) and is maintained as a module within SAM.gov. The system aggregates several categories of records:

• Terminations for cause or default on federal contracts.
• Defective pricing determinations under the Truth in Negotiations Act.
• Contractor performance information from the Contractor Performance Assessment Reporting System (CPARS) for contracts above $750,000.
• Administrative agreements arising from suspension or debarment proceedings.
• Criminal convictions and civil judgments related to fraud, antitrust violations, bribery, tax evasion, or similar offenses.
• Suspension and debarment actions under FAR Subpart 9.4.
• Determinations of non-responsibility that include a finding of a lack of satisfactory performance record or integrity.

FAR 9.104-6 requires contracting officers to review all FAPIIS records for a contractor and its principals before award. When a record exists, the contracting officer must consider whether it affects the contractor's present responsibility. Contractors have the right to submit information rebutting or explaining adverse FAPIIS records, and the contracting officer must consider that rebuttal as part of the responsibility determination.

FAPIIS records are generally retained for six years. The public can access most records; however, some integrity information is accessible only to government users.

Why it matters for contractors

A single adverse FAPIIS record -- especially a termination for default or a fraud-related judgment -- can disqualify an otherwise technically strong offeror. Contractors should monitor their own FAPIIS profile regularly through SAM.gov, because errors in government-entered records can be contested and corrected. When a contractor is aware of an adverse record, preparing a proactive rebuttal statement before a competition closes is far better than addressing the issue reactively after the contracting officer flags it.

Contractors involved in mergers, acquisitions, or corporate restructurings must evaluate whether the acquired entity carries FAPIIS records that could affect the combined firm's eligibility. The integrity record follows the legal entity, not the personnel.

Example

A mid-tier defense contractor submits a proposal for a $40 million services contract. The contracting officer pulls the FAPIIS record and finds a termination for default from three years ago on a different agency's contract. The contractor had submitted a detailed explanation of the circumstances -- a subcontractor failure and a disputed cure notice -- at the time the record was entered. The contracting officer reviews the rebuttal, considers the contractor's improved past performance ratings since then, and determines that the contractor is presently responsible. The contract is awarded. Without the proactive rebuttal on file, the outcome might have been different.