FAPIIS

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The Federal Awardee Performance Integrity Information System (FAPIIS), now called Responsibility/Qualification in Sam.gov, was created in response to taxpayers demanding more transparency in how government funds are allocated and spent. As mandated by the Federal Acquisition Regulations (FAR) 9.104-6 and Uniform Guidance (UG) 2 CRF 200.206, Federal awarding agencies of contracts, grants, and cooperative agreements MUST have a framework in place for evaluating risks posed by applicants prior to making a new award and MUST check FAPIIS for any pertinent information. Risk evaluations may involve the following criteria:

  • Financial stability of the recipient
  • Management systems and standards in place
  • History of performance – including timeliness of applicable reporting requirements and conformance to terms and conditions of previous awards
  • Audit reports and findings
  • Ability to effectively implement requirements
  • Suspension and debarment compliance

Reminder: Recipient/Applicant = CSU. Agencies and Sponsors award grants and contracts to CSU, not PIs.

The ‘History of Performance’ has become a hot topic with major Federal Sponsors like NSF. NSF has clarified its expectations around project reporting requirements in Important Notice No. 148. They have made it clear they consider late technical reporting to be a significant problem and that they will report the issue in Sam.gov.

NSF Technical Reporting Guidelines

  • Annual technical reports are DUE 90 days before the end of the budget period.
  • Final technical and outcomes reports are DUE 120 days after the end of the project.

IMPORTANT: Any report that is over 1 year late will be reported on FAPIIS as a Recipient’s Material Failure to Comply with the terms and conditions of an award.

What does this mean to CSU? To the Research Community?

While NSF has been regularly communicating its expectations, all Federal awarding agencies have the same requirements under FAR and UG for risk assessment. Also, Per UG 2 CFR 200.339, Federal awarding agencies have options for dealing with non-compliance. These range from temporarily withholding payments to the non-Federal entity to withholding further Federal awards.

Bottom-line: Non-compliance on one award could affect other awards at the same institution.

Updated 6/10/2025