A new broad-brush federal database of contractor integrity and performance is now online. The Federal Awardee Performance and Integrity Information System (FAPIIS) was a requirement of the fiscal 2009 Defense authorization act.

Contracting officers in agencies governed by the Federal Acquisition Regulation must consult the database for any procurement worth more than the simplified acquisition threshold--currently $100,000, but likely to be raised to $150,000.

FAPIIS includes data already collected in the Excluded Parties List System, a database of disqualified contractors. However, it now also centralizes less-onerous contracting officer determinations of vendor non-responsibility, records of contract terminations for default or cause, defective pricing determinations and agreements that resolved a contractor suspension or debarment. Plus, it also lists contractor self reports of criminal convictions, civil liabilities and adverse administrative actions.

"With new tools like FAPIIS, additional resources, and an increased priority on oversight and accountability, we are cutting waste and working to giving the American people the effective and efficient government they deserve," Office of Management and Budget Director Peter Orszag wrote in his official blog.

However, federal contractors have expressed worry that the database is too broad. Payment of a civil liability might occur without an admission of wrongdoing. A defective pricing determination is often easy to make because submissions of complex "cost or pricing data" must be legally certified as "accurate, complete and current" as of a particular date, terms that mean even good-faith submissions can contain unintentional inaccuracies. Confusion also often exists as to when defective pricing actually occurs.

The FAR says that cost or pricing data "do not indicate the accuracy of the prospective contractor's judgment about estimated future costs or projections," but it's nonetheless often treated as a binding estimate.

For more:
- check out the final Federal Register FAPIIS notice (.pdf)
- see Peter Orszag's blog post
- see the GPO's FAR site (parts one through 51)

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