Government Contracts Legal Forum

Category Archives: Reporting and Disclosure

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Contractors Can Review and Object to Public Release of Information in FAPIIS

Posted in Reporting and Disclosure
On January 3, 2012, the FAR Council issued a final rule to implement a congressional mandate that the public have access to all information (excluding past performance reviews) in the Federal Awardee Performance and Integrity Information System ("FAPIIS"). FAPIIS was created in 2010 as a one-stop shop for contracting officers to review information about contractors’ business … Continue Reading

Department of Defense Proposes Expanded Property Reporting Rule

Posted in Reporting and Disclosure
On October 19, 2011, the Department of Defense (“DoD”) proposed a new rule to amend DFARS § 252.211-7007 to remove the $5000 threshold from reporting requirements for Government-furnished property.  The proposed rule would require contractors to report Government-furnished property to the DoD Item Unique Identification (“IUID”) registry regardless of value.  DoD states that the intent … Continue Reading

Draft Executive Order Requiring Broad Contractor Disclosure of Political Contributions Faces Strong Opposition from Industry and Congressional Republicans

Posted in Reporting and Disclosure
On April 13, 2011, the Obama administration released a draft executive order called “Disclosure of Political Spending by Government Contractors.” This executive order, if implemented, would instruct the FAR Councils to amend the FAR to require significant disclosures about contractor political contributions to be made as part of any proposal submitted by a firm seeking a federal … Continue Reading

Public Access To FAPIIS

Posted in Reporting and Disclosure
As we blogged previously, as of today – April 15, 2011 – the public has access to all information (excluding past performance reviews) in the Federal Awardee Performance and Integrity Information System (“FAPIIS”). FAPIIS was created in 2010 as a one-stop shop for contracting officers to review information about prospective contractors’ business ethics, integrity, and … Continue Reading

Beware: Government to Release Private Contractor Information Contained In FAPIIS

Posted in Reporting and Disclosure
On January 24, 2011, the FAR Council issued an interim rule to implement a congressional mandate that the public must have access to all information (excluding past performance reviews) in the Federal Awardee Performance and Integrity Information System ("FAPIIS"). FAPIIS was created in 2010 as a one-stop shop for contracting officers to review information about … Continue Reading

In Case You Missed Our FFATA Webinar

Posted in Reporting and Disclosure
On September 20, hundreds of government contractors joined us for a webinar about the new executive compensation and first-tier subcontract award reporting requirements. It was a lively discussion and we explored some of the challenges relating to this new requirement. In case you missed it, the webinar is now available in its entirety by clicking … Continue Reading

New Reporting Requirements For Recipients Of Grants and Other Forms of Federal Financial Assistance

Posted in Reporting and Disclosure
On September 14, 2010, OMB issued two regulations implementing the Federal Funding Accountability and Transparency Act of 2006 requirements applicable to recipients of federal financial assistance. The first (pdf.) requires (among other things) that for any new award made after October 1, 2010, applicants and recipients of grants and cooperative agreements must register in the Central Contractor … Continue Reading

Webinar about Reporting of Executive Compensation And Subcontract Awards

Posted in Reporting and Disclosure
Please join us for a webinar on Monday, September 20 at 2 pm ET for a discussion of the new rules requiring many contractors to report information about executive compensation and awards to subcontractors. During this webinar, we will cover many topics, including: Which companies must report executive compensation information? How is executive compensation calculated? How … Continue Reading

Reporting Requirements For Executive Compensation And First-Tier Subcontract Awards

Posted in Reporting and Disclosure
We have previously provided information about the interim FAR Rule implementing the Federal Funding Accountability Act of 2006, as amended by the Government Funding Transparency Act of 2008. The Rule, which is already in effect, requires many government contractors to report information about their executives’ compensation, their first-tier subcontractors’ executive compensation, and information about their first-tier … Continue Reading

FAPIIS — The Government’s Collection Of Information Via CCR Is Causing Questions And Uncertainties

Posted in Reporting and Disclosure, Responsibility
We have previously provided information about the final FAR Rule implementing the Federal Awardee Performance and Integrity Information System, known as FAPIIS. This Rule, which became effective on April 22, 2010, requires many government contractors to provide certified disclosures pertaining to certain administrative, civil, and criminal proceedings. The Government is collecting this information via a series … Continue Reading

Join us for a webinar about new disclosure requirements

Posted in Reporting and Disclosure, Responsibility
On Thursday, May 6, from 2:00 pm – 3:30 pm ET, please join Angela Styles, Shauna Alonge, Amy O’Sullivan and Peter Eyre from Crowell & Moring’s Government Contracts Group for an in-depth discussion of the final rule amending the FAR to implement the Federal Awardee Performance and Integrity Information System, known as FAPIIS. As discussed in … Continue Reading

FAPIIS — Significant New Disclosure Requirements (And Many Unanswered Questions)

Posted in Reporting and Disclosure, Responsibility
Tomorrow – April 22, 2010 – is the effective date of the final FAR Rule (.pdf) implementing the Federal Awardee Performance and Integrity Information System, known as FAPIIS. If the expected value of a contract (or grant) exceeds $500,000, agencies must insert a new implementing clause (FAR 52.209-7) that requires certified disclosures from contractors pertaining to certain … Continue Reading