Understand the Implications of FAPIIS, Integrity Guidance with Free Thompson Webinar

August 21, 2015 | By Jerry Ashworth | Post a Comment

Laptop-Work2-300x195You may have seen our blog post from earlier this month about an Office of Management and Budget (OMB) final guidance on the Federal Awardee Performance and Integrity Information System (FAPIIS) and Section 872 of the Duncan Hunter Defense Authorization Act of 2009 (Pub. L. 110-417) and asked yourself, “What exactly is this, and how does it really affect my federal award?” Well, this new guidance can be especially harmful for high-risk grantees and those that have taken part in criminal, civil or administrative proceedings. The federal government essentially is creating a list of those nonfederal entities who have poor performance or low integrity, and nonfederal entities should be aware if they may be included on this list. Now is the time to find out more, and Thompson is hosting a free webinar to keep you informed.

Here’s some background. Section 872 of the Duncan Hunter Act requires federal agencies to qualify federal contractors based on integrity data and to post their determinations in a federal web portal and repository, currently FAPIIS. OMB recently issued final guidance to extend Section 872 from the federal contract community to the grants community. Applicants, therefore, will now be subject not only to merit and risk reviews, but also to integrity reviews. Recipients will face both risk and integrity reviews. A poor review can label you as “not qualified” for federal funds, and will be posted publicly in FAPIIS for five years. The uniform guidance and the Code of Federal Regulations (C.F.R.) were revised on July 30 to incorporate language from the Section 872 guidance, and these provisions will become applicable Jan. 1, 2016.

Because this “not qualified” designation will be posted in FAPIIS for five years, any federal agency planning to make a federal award will see that designation. This new protocol is not an official suspension or debarment, but it sure can affect a nonfederal entity’s eligibility, not only for one award, but for all federal awards.

There are numerous intricacies to the Section 872 guidance, and several sections of the uniform guidance were amended. To keep you aware of these changes, our free webinar, “This Just In: OMB Revises Uniform Guidance!” will keep you prepared. The webinar will be hosted by Karen Norris, managing editor for Thompson grants publications. There are three ways to register for the webinar: order online; call 800-677-378, or fax 800-999-5661. Register today.

Does the potential for being included on a “not qualified” database for five years scare you? What steps to you plan to take to avoid from being deemed “not qualified?” Let us hear from you.


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