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OMB Expands FAPIIS to Cover Grants and Cooperative Agreements

Client Alert | less than 1 min read | 07.28.15

On July 22, 2015, OMB issued final guidance that – effective January 1, 2016 – expands the Federal Awardee Performance and Integrity Information System (FAPIIS) to cover federal grants and cooperative agreements. Applicants and recipients will have to disclose significant information about civil, criminal, and administrative proceedings that occurred in connection with the award or performance of a federal grant, cooperative agreement, or contract; for their part, agencies must consider information in FAPIIS prior to award as part of the analysis of the applicant's integrity and performance history.


Insights

Client Alert | 2 min read | 12.29.25

FYI – GAO Finds Key Person “Available” Despite Accepting Employment with a Different Company

GAO’s key personnel rule is well-known—and often a source of frustration— amongst government contractors.  Proposed key personnel who become “unavailable” prior to contract award—especially where they have accepted employment with a different company—may doom an offeror’s proposal by rendering it noncompliant with solicitation requirements.  But GAO’s recent decision in FYI – For Your Information, Inc., B-423774, B-423774.2 (Dec. 19, 2025) provides some potential relief from that rule. ...