In a recent article for Reuters, I warned of the potential consequences if government contractors fail to comply with their disclosure obligations. I outlined the types of proceedings government contractors with federal contracts and grants with a total value greater than $10 million must report on the Federal Awardee Performance Integrity and Information System (FAPISS) in accordance with FAR 52.209-7, which include:
- Criminal proceeding resulting in a conviction or other acknowledgment of fault.
- Civil proceeding resulting in a finding of fault with a monetary fine, penalty, reimbursement, restitution, and/or damages greater than $5,000, or other acknowledgment of fault.
- Administrative proceeding resulting in a finding of fault with either a monetary fine or penalty greater than $5,000 or reimbursement, restitution, or damages greater than $100,000, or other acknowledgment of fault.