Comment on FR Doc # E9-23893

November 1, 2009 General Services Administration, Regulatory Secretariat Attention: Hada Flowers 1800 F Street, N.W., Room 4041 Washington, D.C. 20405 RE: FAR Case 2008-027, Federal Awardee Performance and Integrity Information System (FAPIIS) Dear Ms. Flowers: The Coalition for Government Procurement appreciates the opportunity to comment on the proposed rule to amend the Federal Acquisition Regulation (FAR) to implement Section 872 of the Duncan Hunter National Defense Authorization Act for Fiscal Year 2009. The Coalition for Government Procurement is a non-profit association of over 350 firms selling commercial services and products to the federal government. Our members comprise small, medium, and large businesses actively engaged in federal business. Our members collectively account for approximately 70% of the sales generated through the GSA Multiple Award Schedules program and about half of the commercial item sales made to the government each year. Section 872 requires the General Services Administration to establish and maintain a data system containing specific information on the integrity and performance of covered Federal agency contractors and grantees. Section 872 also requires awarding officials to review the data system and consider other past performance information when making any past performance evaluation or responsibility determination. The Coalition has several comments to make on the proposed rule. Accurate Data in the System While transparency is important, and supported by industry, for the system to work properly government acquisition officials must enter timely and accurate data. In the past, data has been inaccurate or nonexistent. Ensuring accurate data is entered into the system is critical, and better training of the acquisition workforce is needed to ensure this occurs. Information Security Effective information security controls must be in place to protect awardee information. While the rule states the database will be private and only federal officials will have access, federal agencies have struggled with information security in recent years. Contractors providing sensitive information must be protected from security breaches. Competition could be adversely effected should sensitive information about a contractors products and pricing be made public. Redundancy and Cost to Government Finally, the proposed information system would impose significant costs on the government and may be unnecessary as the government already has two other databases with similar information, the Past Performance Information Retrieval System (PPIRS) and the Contractor Performance Assessment Reporting System, which includes past performance information from agencies. Further, the Excluded Parties List System contains information on companies that are currently suspended or debarred from working with the government. Thank you again for the opportunity to comment. Please let us know if you have any questions or would like to discuss these issues further. Regards, Barbara F. Merola Director of Policy The Coalition for Government Procurement Office (202) 331-0975