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Deciphering the alphabet soup - FAPIIS, CPARS, and PPIRS; don't look for all this in the far

Sheppard Mullin Richter & Hampton LLP
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USA
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April 16 2012

In March 2010, the U.S. Government rolled out a new tool promised to provide a centralized source for all publicly available contractor past performance and integrity information the Federal Performance and Integrity Information System (“FAPIIS”

FAPIIS: update on government FAPIIS postings: quick contractor reaction required

Sheppard Mullin Richter & Hampton LLP
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USA
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January 11 2012

Our previous discussions of the Federal Performance and Integrity Information System (“FAPIIS”) posted here in June 2010 and March 2011, urged contractors generally to manage affirmatively FAPIIS and, specifically, to: (i) place a high priority on entry and updating of data into FAPIIS; (ii) take advantage of every opportunity to comment on, explain or rebut information posted in FAPIIS; and (iii) be alert for Government posting of harmful information, in particular information potentially protected from disclosure by a Freedom of Information Act disclosure exemption, Exemption 4

Who's in charge? The GAO, the FAR Council, and jurisdiction over task order bid protests

Sheppard Mullin Richter & Hampton LLP
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USA
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July 15 2011

We’ve previously complained about the FAR Council’s tendency to take too much time to issue rules that entail consideration of complex subject matter, as indicated, for example, by the 13 years during which the Council dallied before issuing final rules for commercial off the shelf items, discussed here

"Give me your huddled masses": COFC still beckons to protesters

Sheppard Mullin Richter & Hampton LLP
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USA
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July 15 2011

The U.S. Court of Federal Claims' (“COFC”) decision in Jacobs Technology, Inc. v. United States, No. 11-180C, 2011 WL 2044581 (Fed. Cl. May 26, 2011) (“Jacobs Technology”) does double duty, affirming once again the availability of the COFC as a convenient forum for aggrieved offerors challenging a resolicitation and providing us a useful primer on the perennial issues of jurisdiction, ripeness, standing, and agency discretion in the context of pre-award protests

OFCCP's proposed equal employment opportunity rules: more on-site investigations, more data collected from contractors, closer scrutiny of contractor affirmative action

Sheppard Mullin Richter & Hampton LLP
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USA
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June 16 2011

The Office of Federal Contract Compliance Programs (“OFCCP”) recently proposed two rules that would, among other things, enhance the agency's investigative and enforcement capabilities and substantially increase the amount of EEO-related data it will collect from contractors

Terminations for convenience and creedence clearwater revival: "bad moon rising"

Sheppard Mullin Richter & Hampton LLP
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USA
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April 18 2011

It now is generally accepted that the federal budget must be reduced drastically, although just how drastically and where is still a matter for debate

FAPIIS: an update on the integrity database for government contractors

Sheppard Mullin Richter & Hampton LLP
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USA
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March 16 2011

We last discussed the Federal Awardee Performance and Integrity Information System ("FAPIIS") in June 2010

FAPIIs: an update on the integrity database for government contractors

Sheppard Mullin Richter & Hampton LLP
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USA
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March 16 2011

We last discussed the Federal Awardee Performance and Integrity Information System ("FAPIIS") in June 2010

Department of Labor attempts to extend the "Christian Doctrine" to subcontracts

Sheppard Mullin Richter & Hampton LLP
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USA
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August 17 2010

It has long been questioned whether the "Christian Doctrine," pursuant to which mandatory contract clauses reflecting core procurement policy are incorporated into government prime contracts by operation of law, can be used to incorporate such clauses into subcontracts

DOD proposed rule would eliminate provisional award fee and defer substantial award fee payments

Sheppard Mullin Richter & Hampton LLP
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USA
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August 4 2010

The Department of Defense recently proposed a rule that would revise guidance for award-fee evaluations to require the incorporation of award-fee plans into all DOD award-fee contracts