Thursday, July 19, 2012

Enhancements Sought for Contractor Integrity Databases

The Government is soliciting public comment on how to improve contracting officers' access to relevant information about contractor business ethics. The Government implemented a database called FAPIIS (Federal Awardee Performance and Integrity Information System) back in 2010 to collect performance information. Contracting officers now routinely consider information contained in this database when making responsibility determinations prior to awarding contracts.

Information in FAPIIS comes from different sources, including the CCR (Central Contractor Registration) and directly from contracting officers for past performance data, suspensions, debarment, termination for default, etc. to collect information about contractor performance. Government contractors submitting bids greater than $500 thousand having more than $10 million in active contracts must report criminal convictions, civil liability, and adverse administrative actions into CCR.

The problem that contracting officers have been finding is in the unique identifiers that contractors use to identify themselves. Information in FAPIIS is organized by DUNS numbers (Data Universal Numbering System). However, the system, as it is currently constructed, requires contractors to maintain a unique DUNS for each physical location or different business address in an organization. The FAPIIS does not associate all DUNS numbers of a corporate entity. Thus, a contracting officer cannot determine if there may be relevant information reported under different DUNS numbers assigned to other locations at which the entity named on the contract conducts business or under different DUNS numbers assigned to other parts of the corporate entity that are not named on the contract, such as an affiliate or subsidiary, the share the same management, infrastructure, and systems as the entity uses in doing business with the Government.

For information on how you can submit ideas for fixing this conundrum, click here.

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