The document provides an overview of the Federal Awardee Performance and Integrity Information System (FAPIIS). FAPIIS requires government contracting and grants officers to report contractor and grantee performance information to a centralized database. This includes terminations, non-responsibility findings, and administrative agreements. FAPIIS also collects contractor-reported criminal, civil, and administrative proceedings information. The system is intended to support contracting officers' responsibility determinations by providing a consolidated performance record of potential awardees.

1. Overview
• Purpose & Effect
• FAR Requirements
• EPLS Checks
• EPLS Documentation
• Search Warnings
• Recent UCI Findings
• FAPIIS
• Summary

2. Purpose & Effect
• EPLS purpose – protects government
• Government-wide effect
– https://www.epls.gov
– Contractors debarred, suspended, or proposed for
debarment are excluded from receiving contracts
– Agencies shall not
• Solicit offers from
• Award contracts to
• Consent to subcontracts with these contractors
– Agency head may determine there is a compelling
reason for such action

3. FAR Requirements
• FAR 9.402 Suspension & Debarment Policy
– Agencies shall solicit offers from, award contracts to, and
consent to subcontracts with responsible contractors
only
– Debarment and suspension are discretionary actions that
are an appropriate means to effectuate this policy
– The serious nature of debarment and suspension
requires that these sanctions be imposed only in the
public interest for the Government’s protection and not
for purposes of punishment

4. FAR Requirements (cont)
• FAR 9.405 EPLS, Effect of Listing
– Contractors debarred, suspended, or proposed for
debarment are excluded from receiving contracts, and
agencies shall not solicit offers from, award contracts to,
or consent to subcontracts with these contractors, unless
the agency head determines that there is a compelling
reason for such action
– Contractors debarred, suspended, or proposed for
debarment are also excluded from conducting business
with the government as agents or representatives of
other contractors

5. FAR Requirements (cont)
• FAR 9.405(d) Contracting Officers Shall –
– After the opening of bids or receipt of proposals, the CO
shall review the EPLS
• Bids shall be entered on the abstract, then rejected
• Proposals, quotations, or offers shall not be evaluated – no
discussions
– Immediately prior to award, the CO shall again review
the EPLS

6. FAR Requirements (cont)
• FAR 9.405 Effects of Listing on Contract Award
– Contracting Activities Shall Not –
• Award new contracts
• Place orders exceeding the guaranteed minimum under IDIQ
contracts
• Place orders under optional use FSS contracts, BPAs, or BOAs
• Add new work, exercise options, or otherwise extend the
duration of current contracts or orders

7. FAR Requirements (cont)
• Effect of Listing – Compelling Reason to Continue
– Written Determination: When an agency determines that
a compelling reason exists for it to continue business
with a contractor that is debarred, suspended, or
proposed for debarment, it must provide written notice of
the determination to the GSA, Office of Procurement
Policy. 10 U.S.C. 2392(b); DFARS 209.405
• Examples: (i) only one source for service/supply; (ii) urgency;
(iii) agency agreement; (iv) national defense requires continued
dealings
– Request must address (i) efforts to develop alternate
sources and (ii) impact. AFFARS 5309.405

8. FAR Requirements (cont)
• Continuation of Current Contracts
– Notwithstanding the debarment, suspension, or
proposed debarment of a contractor, agencies may
continue contracts or subcontracts in existence at the
time the contractor was debarred, suspended, or
proposed for debarment unless the agency head directs
otherwise. FAR 9.405-1
– Termination of existing contracts requires T4D, T4C, or
cancellation
– Continue to administer the contract
• Consider appropriate contractual remedies (including past
performance)

9. Two Checks Required
• FAR 9.405(d)
• Upon receipt of proposal(s)
– Could be accomplished in one check if award is made
immediately
• Immediately prior to award
– Upon finalization of file & signature by CO
– Will address “immediately” later in the training
Checks required for Competitive and Sole Source

10. Recommended EPLS Check
• Prior to release of solicitation
– If not performed (and documented) as part of source list
development, CO could accomplish & document prior to
release
– Equally applicable in sole source and competitive
situations

11. What is . . .
• Immediately prior to award?
– Within 24 hours of contracting officer signature
– The closer to signature the better!!!
• Why is this important?
– 1100 – Buyer completes file by running EPLS check and
placing it in the file; provides file to CO for signature
– 1400 – Agency inputs contractor suspension into EPLS
– 1700 – CO signs action based upon earlier EPLS check;
awards to debarred/ suspended contractor
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12. Actions Requiring EPLS
Check
• FAR 9.405-1 provides overarching guidance
• Check for new contracts, orders, UCAs,
definitization of UCAs, etc.
• Modifications: Check for actions that add new
work in the broad sense
– Includes “changes” clause work, exercise an option, or
extend duration of contract or order
• May not be required for admin mods or
incremental funding IF work required and
performance/delivery period unchanged
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13. Actions Requiring EPLS
Check (cont)
• Check EPLS before consenting to subcontracts
• Ktrs shall not enter into subcontract
> $30K w/company that has been debarred,
suspended, or proposed for debarment
– Compliance checked during Contractor Purchasing
System Reviews
– Additional documentation in prime contract file should
not be necessary
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14. Actions Requiring EPLS
Check (cont)
• Gov’t extending the period of performance
– Must check EPLS
– Doesn’t matter why period of performance extended
• Orders under a requirements contract
– EPLS checked at initial award
– Subsequent checks not required
– Contract requirement is for all of the government’s
requirements for a period of time

15. EPLS Documentation
• What is acceptable documentation of EPLS
review?
– Screen prints from EPLS are acceptable
– Should include all of the query results
• If results are voluminous, refine your search
– “Conservative (thorough) CO” may also include a brief
memo
– Signature on screen prints not required
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16. Search Warnings
• Exact Name
• CAGE Code/DUNS Number
• Multiple field advanced search
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17. 17

18. 18

19. Exact Name Warning
• Partial Name search recommended
• Exact Name search NOT recommended
– Will return results only if query is identical to name of
record in EPLS
– Including any punctuation, prefixes, or suffixes
APM ≠ APM, LLC
APM LLC ≠ APM, LLC
John Doe Jr ≠ John Doe, Jr.
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20. CAGE/DUNS Warning
• Search by CAGE Code or DUNS may not be
sufficient
– EPLS does not have CAGE Code or DUNS identifiers
for all firms
• Partial Name search also should be performed if
no results are obtained from a DUNS or CAGE
search
– Partial name must be spelled correctly
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21. Advanced Search Warning
• More than one advanced search criterion may be
selected
• Not all need to be selected to perform search
• Many searches will not return any results if more
than two criteria are selected
– Each criterion will reduce the number of returned
search results
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22. Recent UCI Findings
• Lack of one or both EPLS checks
• Not checking EPLS for Delivery Orders/Task
Orders
• Lack of documentation

23. Effect of FAPIIS
• Federal Awardee Performance and Integrity
Information System (FAPIIS)
• NDAA, Section 872 requires development of a
‘database’ on potential awardees for data to
support award decisions
• Decision made to leverage the capabilities of
CPARS, CCR, and PPIRS to satisfy the 872
requirements

24. Effect of FAPIIS (cont)
• FAPIIS – Sources of Information
– EPLS
– Past Performance Information Retrieval System (PPIRS)
and Contractor Performance Assessment Reporting
System (CPARS)
– COs will provide information on non-responsibility
determinations and T4Ds
– Suspension/Debarment Official will provide summaries of
Administrative Agreements
– Contractors (>$10M contracts/grants) required to provide
information relating to criminal, civil, and administrative
proceedings

25. Phases
• Initial Operational Capability (IOC) Deployed March
22, 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

26. Phases (cont)
• Subsequent Phases
– Required – Ability to collect administrative agreement
information from suspension / debarment officials
(pending requirements definition for identification of
individuals) – planned for Fall 2010 release
– OFPP considering lowering the threshold at which
vendors have to provide criminal/civil/administrative
proceeding information to the simplified acquisition
threshold
– OFPP considering expanding the criminal/civil/
administrative proceeding information to cover state
contracts/grants in addition to federal contracts/grants

27. Regulation Changes
• FAR Case 2008-027 final rule, effective April 22,
2010, was published March 23, 2010
– Established the FAPIIS database
– Contracting officers report non-responsibility
determinations to FAPIIS
– Contracting officers place new provision/clause
52.209-7/8 (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)

28. Regulation Changes (cont)
• FAR Case 2008-016 is anticipated for final rule in
Q3FY10 and expands the data in FAPIIS by
requiring 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

29. FAPIIS Bottom Line
• Ultimately checking FAPIIS will fulfill the
requirement to check EPLS
• Robustness not there yet
• Continue to check EPLS

30. Summary
• Check EPLS twice!
• Document the file!
– Partial Name search is preferred method
– Goal is NOT to obtain a results page without any
listing
– Goal is to conduct broad enough search to capture
contractor if they are listed on EPLS
– Additional search tips can be found in the EPLS User
Manual
– https://www.epls.gov/EPLS%20Public%20Users
%20Manual.pdf
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31. Overview
• NDAA, Section 872 requires development of a ‘database’ on
potential awardees for data to support award decisions
– 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
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32. Data Elements
• 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 *
* Mandatory Field

33. Data Elements (cont)
• 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

34. Getting Set Up
• If you are already using CPARS and PPIRS, accessing the
FAPIIS modules is simply another ‘role’ that the focal points
can authorize for users
• If you are not already using CPARS and PPIRS, a
representative from the Senior Procurement Executive's
staff should contact the CPARS Program Management
Office (PMO) to discuss approaches for establishing focal
points
– PMO will assist each agency with this process. An access request
form must be submitted for each focal point.
• Online training is available to assist new users
• A FAPIIS User Manual is available for new users

35. FAPIIS
• In spring 2009, determination is made by the 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
• DoD led cross-federal agency/functional design team
meetings to flesh out the requirements and design

36. Effect of FAPIIS
Proposed FAR Rule: Federal Awardee
Performance and Integrity Information System (74
Fed. Reg. 45579)
– Requires GSA to establish and maintain a data system
containing specific information on the integrity and
performance of covered contractors.
– Requires awarding officials to review the data system
and consider other past performance information when
making any past performance evaluation or
responsibility determination