OFPP Championing Better Contractor Performance Reporting

FAPIIS, rolled out in March 2010, promised to provide a centralized source for all publicly available contractor past performance and integrity information.  The FAPIIS database aggregates several sources of information for contracting officers to use in responsibility determinations.  It provides access to information from the

Contractor Performance Assessment Reporting System (CPARS), the Central Contractor Registration (CCR) database, and suspension/debarment information from the Excluded Parties List System (EPLS).  Originally, only available to federal employees, most FAPIIS information became available for public access in January 2012.

On March 6^th, Jordan released a memo to Chief Acquisition Officers (CAO) and Senior Procurement Executives (SPE) with new policies aimed at improving the quantity and quality of FAPIIS information.  “Improving the collection and use of information about contractor performance and integrity strengthens the government’s ability to efficiently purchase goods and services from private industry,” Jordan states in the memo.  Jordan believes a strong foundation has been set with FAPIIS, but he stressed the need for more reporting in order for contracting officers to rely on the information in making source selection and award decisions.

The memo states that its purpose is to help agencies improve the collection and use of performance and integrity information through:

• Establishing a baseline for reporting compliance
• Setting aggressive performance targets that can be used to monitor and measure reporting compliance
• Ensuring the workforce is trained to properly report and use this information

The memo goes on to establish new government-wide annual performance reporting targets, and suggestions for prioritizing high-risk actions, such as cost reimbursement or time-and-material contracts.  CAOs and SPEs should communicate to the workforce the importance of using past performance information, motivate and hold accountable employees for improving the data, and recognizing acquisition professionals who contribute to improvements to the system.

Guidelines for contractor-provided and government-provided information for FAPIIS were also specified in Jordan’s memo.  Government-provided information such as nonresponsibility determinations, terminations for default of cause, and suspensions and debarments must be reported accurately and in a timely manner.   The information should be reviewed quarterly to ensure it is reported to the appropriate performance system.  Additionally, contracting officers should perform sampling and routine quality reviews of contractor-provided information to validate data integrity.

Contractors should be mindful of increased use of FAPIIS in making contracting decisions and measuring contractor past performance, and agencies’ added emphasis and efforts to improve the quantity and quality of the system information.  According to Jordan, "improving the collection and use of this information will increase agencies’ ability to deliver better outcomes and increase productivity."