As part of determining financial responsibility in awarding grants, is it acceptable to check FAPISS instead of EPLS? Or should both be done, or one or the other?
Determining financial responsibility in accordance with §22.415 Standards may be achieved per regulations at DoD Grants and agreements – award and administration (DoDGARs), part 22, §22.420, paragraph(C)(1). The regulations at 22.420(C)(1)say:
(c) In deciding whether a recipient is otherwise qualified and eligible in accordance with the standard in §22.415(d), the grants officer shall ensure that the potential recipient:
(1) Is not identified in the Governmentwide Excluded Parties List System (EPLS) as being debarred, suspended, or
otherwise ineligible to receive the award.
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In response to your question, the DoDGARs makes no reference to using the Federal Awardee Performance and Integrity Information System (FAPISS)in making responsibility determination. In my opinion, making a responsibility determination the government official shall ensure that the potential recipient is not indentified in the EPLS as shown above. Further, in my opinion, nothing precludes a government official from using FAPISS in addition to the EPLS for making responsibility determinations; but, the government official shall use the EPLS. For further reading on FAPISS in lieu of EPLS see the included memorandum at https://acc.dau.mil/CommunityBrowser.aspx?id=496360.