Federal Awardee Performance and Integrity Information System (FAPIIS)

The Federal Awardee Performance and Integrity Information System (FAPIIS) is a government-maintained database that consolidates information about contractor past performance, integrity findings, and responsibility-related determinations. Contracting officers are required by FAR 9.104-6 to review FAPIIS before making a responsibility determination for any award expected to exceed $150,000.

What is FAPIIS?

FAPIIS was established under Section 872 of the Duncan Hunter National Defense Authorization Act for Fiscal Year 2009 and is managed as part of the SAM.gov platform. It aggregates several categories of contractor-related information in a single searchable record.

The types of information recorded in FAPIIS include: terminations for cause or default on federal contracts; administrative agreements between contractors and agency suspension and debarment officials; debarment and suspension actions; determinations of contractor nonresponsibility; DoD contractor performance assessments from the Contractor Performance Assessment Reporting System (CPARS) for contracts above certain thresholds; and information about criminal, civil, and administrative proceedings resulting in convictions or civil judgments related to integrity offenses.

Contracting officers must review FAPIIS and consider any adverse information before determining whether a prospective contractor is presently responsible, as required by FAR 9.103. A finding of non-responsibility based on FAPIIS information can result in a contract not being awarded. Contractors have the right to submit comments in FAPIIS rebutting or providing context for any adverse information recorded about them, and contracting officers must consider those comments in their determination.

Why it matters for contractors

For contractors, FAPIIS is both a risk and a transparency mechanism. Any termination for cause, suspension, debarment, or DoD performance assessment rated below a certain threshold will appear in FAPIIS and be visible to every contracting officer reviewing a future proposal. Adverse FAPIIS entries do not automatically disqualify a firm, but they require the contracting officer to make an affirmative, documented responsibility determination, which adds friction to the award process.

Contractors should regularly review their own FAPIIS record through SAM.gov to identify any inaccurate entries and submit corrective comments promptly. When a firm is aware of an adverse FAPIIS entry, it is generally advisable to proactively address it in proposal submissions or pre-award discussions rather than allow it to surface as a surprise during the review process.

Example

A mid-size construction firm had a federal contract terminated for default three years ago. The termination is recorded in FAPIIS. When the firm submits a proposal for a new federal building project, the contracting officer reviews the FAPIIS record, identifies the prior termination, and requests an explanation. The firm submits a written response explaining the circumstances, documenting that the default was contested and later converted to a termination for convenience, and demonstrating subsequent performance improvement. The contracting officer reviews the response, makes a written affirmative responsibility determination, and proceeds with the award.