Afterthoughts: FAPIIS

Following each Nash & Schooner Hot Topics Webinar event, we interview Professor Ralph Nash to get his thoughts on the topic following the panel discussion.  On September 27, Professors Ralph Nash and Steven Schooner hosted special guest James McCullough, Fried Frank, and Julia Wise, OFPP in a discussion of the Federal Awardee Performance and Integrity Information System (FAPIIS).   What are the key points that you think people should understand or know about FAPIIS? 1)      Contracting Officers have a responsibility to input data very quickly after making determinations; this includes issues covered under the Contracts Disputes Act. Contracting Officers then have the additional responsibility of updating the information as these issues go to litigation and settle. 2)      FAR 52.209-7 & 9, primarily, require contractors with … Continue reading