The Federal Awardee Performance and Integrity Information System (FAPIIS)
is no more. After 12 years, the government pulled the plug on this contractor and grantee responsibility information website, which was based on the Project On Government Oversight’s (POGO’s) Federal Contractor Misconduct Database but never seemed to live up to its potential.
In December, the Office of the Under Secretary of Defense announced that FAPIIS had been “integrated” with the System for Award Management (SAM.gov), a federal contractor and grantee data portal managed by the General Services Administration. The records in FAPIIS — federal contractors’ and grantees’ civil, criminal, and administrative misconduct proceedings and other responsibility information — were migrated over to SAM.gov and are now called responsibility/qualification (R/Q) reports. Instructional videos produced by the General Services Administration explain the integration and how to search SAM.gov for these reports.
We’re pleased to see the government streamlining its online data resources and furthering the goal of creating a one-stop shop for federal contract and grant information. The federal government awards trillions of dollars in contracts and grants, and the public should be given more insight into how that money is being spent. SAM.gov has the potential to be an all-in-one transparency and accountability resource that helps ensure taxpayer funds are awarded only to responsible companies and individuals. Unfortunately, this latest data migration and upgrade leaves much to be desired.
According to a government notice, the new information posted on SAM.gov “will be the same as what was available via the FAPIIS public search.” In other words: It’s the same old wine in a brand new bottle. Contractor past performance reviews are still off limits (we think past performance ratings should be public). In addition, users still must navigate a somewhat confusing, glitchy interface to find data that is often unclear, inaccurate, inaccessible, or missing altogether.
There is a 14-calendar-day delay in the posting of R/Q information, although that is probably the least of the site’s shortcomings. Searching and viewing full R/Q records requires creating a user account and logging in to the site. The raw data is also made available in a spreadsheet file that users can download without having to register or sign in. However, the downloadable dataset lacks certain elements and information included in the online records.
There are also problems with the online records. The most recent downloaded data file contained a little over 3,000 R/Q reports: over 2,480 government-entered records and 560 vendor-entered records. Yet a contemporaneous search of SAM.gov returned only around 2,500 R/Q records. Among the records we couldn’t find on the website were misconduct proceeding information for Lockheed Martin and Leidos. In fact, we couldn’t find any civil, criminal, or administrative proceedings at all on the site.
Searches also came up empty for corporate relationship information (“highest owner,” “immediate owner,” and “predecessors”) that companies may, but are not currently required to, enter into the system. Records for exclusions (suspensions and debarments) lacked descriptions or explanations. When we clicked to view an inactive (expired) exclusion, an error message screen popped up stating, “You don’t currently have access to view this page” and “You do not a [sic] permission to view this page.”
Some R/Q records on SAM.gov have links to downloadable PDFs containing additional information, such as correspondence between the government and the vendor. There are PDFs for some contract termination records, but, as far as we can tell, none for exclusions, administrative agreements, or non-responsibility determinations.
And unfortunately, it appears that SAM.gov was not constructed in a way that meets baseline accessibility standards and best practices. The General Services Administration asserts that it “is committed” to making SAM.gov accessible “for all visitors with disabilities.” However, the site is extremely difficult to access for people who use screen-reading and text-to-speech technology to navigate digital platforms and websites. What makes this all the more inexcusable is that Section 508 of the Rehabilitation Act of 1973 requires the federal government to make its websites and other electronic information accessible for people with disabilities, yet the GSA has for several years been aware of problems with SAM.gov’s compatibility with screen-reading software.
There’s still a long way to go before SAM.gov becomes an essential, all-in-one resource for contractor and grantee responsibility information. For instance, we have long advocated for expanding the types of legal proceedings contractors and grantees must report and extending the length of time those records are available to the public. Our wish list also includes public disclosure of past performance ratings and beneficial owners. Additionally, there should be heightened data reporting standards so the information posted on SAM.gov is clear, accurate, and informative, and an enforcement mechanism that ensures companies and individuals don’t evade their reporting obligations.
“There’s still a long way to go before SAM.gov becomes an essential, all-in-one resource for contractor and grantee responsibility information.”
We will hold the General Services Administration to its promise to make the site accessible to all users. And to ensure all these reforms are implemented and adhered to in the long term, we will push for periodic audits, reviews, and oversight hearings on SAM.gov.
POGO applauds the government for further refining its online data environment. The FAPIIS integration so far has been a disappointment, but it is a start. We will continue to work with the General Services Administration and Congress to address SAM.gov’s shortcomings and help make it a more practical, accessible, comprehensive, and user-friendly resource.