FAPIIS, after the SAM.gov migration.

Where FAPIIS went after the December 2022 migration, what Responsibility/Qualification (R/Q) records actually contain, how to look one up, and what the GAO found about underreporting. The procurement officer's reference for the integrity-data layer of SAM.gov.
/ 01 · FOUNDATION

What FAPIIS is, and what records actually surface.

The Federal Awardee Performance and Integrity Information System was created by Section 872 of the FY2009 NDAA as the federal government's integrity-data layer for procurement: the single repository contracting officers must consult before any award above the simplified acquisition threshold under FAR 9.104-6. It exists to make a contracting officer's responsibility determination defensible.

The records that surface in a FAPIIS / R/Q lookup fall into a defined set:

Contract terminations
Default and cause terminations on federal contracts. The most common record type by volume.
Defective pricing determinations
Findings of deficient cost or pricing data, typically from DCAA-audited primes.
Administrative agreements
Settlements between a contractor and an agency, often in lieu of suspension or debarment proceedings.
Criminal proceedings
Federal or state criminal proceedings connected to a federal award.
Civil proceedings
Civil proceedings resulting in a finding of fault and liability of $5,000 or more, connected to a federal award.
Administrative proceedings
Resulting in disposition of $5,000 or more, including suspension and debarment.
Non-responsibility determinations
Prior agency determinations that the contractor was not responsible.
Past-performance evaluations
CPARS-style narratives. These remain non-public even after migration.

Per the GAO's 2024 review, contract terminations make up the overwhelming majority of records you will encounter on a typical lookup. The other categories matter when they appear, but most R/Q reads are termination reads.

/ 02 · MIGRATION

December 2022: FAPIIS moved into SAM.gov.

The single most useful fact this page can tell you: FAPIIS.gov no longer exists as a standalone portal. GSA completed the integration into SAM.gov on December 12, 2022. The standalone fapiis.gov URL now redirects to sam.gov/fapiis. The records were not deleted, restructured, or renamed at the data layer. They were rebranded.

The new canonical term is Responsibility/Qualification (R/Q) records. R/Q is administered alongside Entity Registration and Exclusions inside the unified SAM.gov experience. Per the Department of Energy's PF 2023-11 transition memo: "The look and feel of the records have changed but the core data and core functions have not changed."

Where did FAPIIS go
If a contracting officer or counsel asks "where did FAPIIS go," the answer is: it went to SAM.gov as Responsibility/Qualification records, December 2022. The fapiis.gov address still works as a 301 redirect. The reporting requirements at FAR 52.209-9 did not change.
/ 03 · WORKFLOW

How to look up R/Q records on SAM.gov.

The pre-2022 anonymous public FAPIIS search no longer exists. R/Q lookups require authentication through login.gov.

Step 1
Go to sam.gov and sign in via login.gov. R/Q access requires authentication; this is a key change from the old FAPIIS public-search experience.
Step 2
Use the main SAM.gov search. Enter the entity's UEI (preferred, survives renames and acquisitions) or CAGE code.
Step 3
Results display with type tags. Entity records and R/Q records appear together; R/Q records are explicitly labeled.
Step 4
Open the R/Q record to see the underlying integrity-data history.
Step 5
For bulk analysis (e.g., diligence across a sub portfolio), use the SAM.gov Data Bank to download Responsibility/Qualification data extracts. These were the FAPIIS data files pre-migration.

Anchor every lookup to UEI rather than legal name. Names mutate through M&A and DBAs; UEI is the canonical identifier post-April 2022. See UEI vs CAGE explained for the broader identifier landscape.

/ 04 · REPORTING

FAR 52.209-9 and the $10 million trigger.

The reporting obligation lives at FAR 52.209-9, prescribed by FAR 9.104-7(c). The clause text is direct: contractors with covered awards must update their FAPIIS / R/Q record "on a semi-annual basis, throughout the life of the contract."

Trigger threshold
Receiving more than $10 million in aggregate federal contract value. Not a per-contract test, aggregate across the contractor's federal portfolio.
What to report
Criminal, civil, and administrative proceedings connected to a federal award, with the $5,000 finding-of-fault threshold for civil and admin matters.
Cadence
Semi-annual update for the life of the contract. Not one-time at award.
Mirror on the grant side
Parallel reporting rules for federal grants live at 2 CFR Part 200 Appendix XII.

GAO-24-106911 documented that the system is materially under-reported in practice: hundreds of unreported terminations and administrative agreements over a five-year sample, with DOD accounting for the largest share of missed entries. The implication for diligence: R/Q is a floor, not a ceiling. A clean record is a positive signal but never a complete picture.

/ 05 · PROCEDURAL WINDOWS

14-day public posting, 7-day dispute, 6-year comment retention.

The public-access mechanics matter because they determine when a contracting officer or sub-vetting prime can actually see a new record. All three rules live at FAR 9.105-2, not at FAR 9.104-6 where the responsibility-review obligation sits.

14 calendar days
Newly submitted information sits in a non-public segment for 14 calendar days before automatic public posting. The clock runs from submission, not from the underlying triggering event. Calendar days, not business days.
7-day contractor dispute
Within 7 calendar days of being notified of a posting, the contractor may assert that information is FOIA-exempt. The agency must remove the posting within 7 calendar days of that assertion.
6-year contractor comment retention
Contractors may post a written comment alongside any record. The comment persists for 6 years. Useful for contextualising terminations that have been remediated or clarified.
Past-performance carveout
Past-performance evaluations remain non-public even after the 14-day window. The public R/Q view never includes CPARS-style narratives. CPARS access is gated separately for federal personnel and contracting officials.
/ 06 · INTERPRETATION

Reading an R/Q record. Termination is not disqualification.

Both contracting officers and primes vetting subs make the same error: treating any negative R/Q entry as a dispositive signal. FAR 9.104-6(c)explicitly directs reviewers to "apply sound judgment in determining the weight and relevance" of the data. Context is the work.

  • A termination for default on a 2017 IT contract for a now-divested business unit is materially different from a 2024 termination on the same NAICS the offeror is bidding on now. Recency, scope match, and corporate continuity all matter.
  • An administrative agreement with the Interagency Suspension and Debarment Committee (ISDC) typically signals that the contractor self-corrected and is operating under a compliance regime. Frequently a positive signal, not negative.
  • A criminal proceeding record may be at the indictment stage, not conviction. Read disposition fields. An unresolved indictment is a flag for present-responsibility analysis but not a final fact.
  • Defective pricing findings cluster around DCAA-audited primes. Their absence on a non-audited sub does not imply clean pricing; it implies the sub has not been audited at scale.
  • The contractor's 6-year comment is signal too. Read it. Comments that reframe a termination with documented remediation are different from comments that argue the agency was wrong.
/ 07 · PITFALLS

Common mistakes.

  • Searching for "FAPIIS" expecting a separate portal. It does not exist anymore. fapiis.gov redirects to sam.gov/fapiis as of December 2022.
  • Treating a clean R/Q record as a green light. Per GAO-24-106911, the database is materially under-reported. R/Q is a necessary but insufficient check. Pair with the SAM exclusions read, the DOL Wage and Hour search, and court-records work.
  • Stopping at the prime.Subcontractors above the $10 million aggregate threshold have their own R/Q records. Primes vetting subs should pull each tier-1 sub's record, not just rely on the prime's.
  • Confusing CPARS narratives with public R/Q view. Past-performance evaluations are not public, even after the 14-day window. If you are looking for CPARS, you need separate gated access.
  • Conflating FAR sections. The 14-day and 7-day rules live at FAR 9.105-2. The responsibility-review obligation lives at FAR 9.104-6. The reporting clause is FAR 52.209-9. Different sections, different jobs.

Where DiligenceDesk fits: the orchestrator pulls SAM.gov R/Q signals alongside exclusions, the ITA Consolidated Screening List, USAspending performance context, and the rest of the source matrix in the verdict ladder. The under-reporting gap GAO documented is exactly why diligence cannot stop at any single source.

Run an R/Q-aware diligence audit on any federal vendor.

SAM.gov R/Q records, exclusions, ITA sanctions, DOL enforcement, Section 889 hardware, and four more sources reconciled in seconds.