Every federal grant or cooperative agreement a research institution accepts comes bundled with a set of integrity checks the institution must run on itself and on the parties it subcontracts, subawards, or purchases from. Four of these — FAPIIS review and disclosure, suspension and debarment screening, the Build America, Buy America Act (BABA) domestic-content preference, and Section 889’s telecommunications-equipment ban — are frequently handled inconsistently because most public guidance on them is written for federal contractors, not universities and research institutes receiving grants. This guide maps each requirement to when a research institution actually has to act on it.
What FAPIIS is, and who can see what’s in it
The Federal Awardee Performance and Integrity Information System (FAPIIS) was created by Section 872 of the Duncan Hunter National Defense Authorization Act for FY2009 (Public Law 110-417) to give federal officials a central, government-wide record of an awardee’s performance and integrity history before making award decisions. FAPIIS has two tiers of visibility:
- Public FAPIIS — a subset of the data, visible to anyone, accessible through SAM.gov.
- Non-public FAPIIS — the full record, visible only to federal officials making responsibility determinations, embedded in SAM.gov’s “responsibility/qualification” records for an entity.
Under 2 CFR 200.206, before making an award where the federal share exceeds the simplified acquisition threshold, the awarding agency must review the applicant’s information in SAM.gov — including its non-public FAPIIS records and, since the 2024 Uniform Guidance revision, OMB-designated Do Not Pay Initiative databases under the Payment Integrity Information Act of 2019 — as part of assessing the applicant’s risk, integrity, and business ethics. A poor record is not an automatic bar to funding; the agency can still make the award if it documents why the information is not relevant or applies risk-mitigating award conditions instead.
The recipient side: mandatory FAPIIS self-disclosure and the $10 million threshold
This is the part institutions most often miss. Appendix XII to 2 CFR Part 200 (the “Award Term for Recipient Integrity and Performance Matters”) requires a non-federal entity to self-report into SAM.gov once the total value of its currently active federal grants, cooperative agreements, and procurement contracts exceeds $10,000,000 at any point during the period of performance of a covered federal award. Once that threshold is crossed, the recipient must report, semiannually, any of the following that reached final disposition within the preceding five years and relate to the award(s):
- Any criminal proceeding that resulted in a conviction.
- Any civil proceeding that resulted in a finding of fault and liability with monetary damages, penalties, or fines exceeding $5,000.
- Any administrative proceeding that resulted in a finding of fault with a monetary penalty of $5,000 or more, or restitution/damages/other payments of $100,000 or more.
- Proceedings resolved by consent or compromise where fault was acknowledged, even without a formal finding.
If nothing has changed since the last report, the institution still affirms “no new information to report” — silence is not an acceptable substitute. This obligation sits at the institutional level, aggregated across every active federal award, which is why it’s usually owned centrally by the sponsored-programs or research-compliance office rather than left to individual PIs or departments.
Don’t confuse this with the 2 CFR 200.113 disclosure duty
A separate, narrower obligation trips up institutions that assume “we’re under $10 million, so FAPIIS doesn’t apply to us.” 2 CFR 200.113 requires any applicant, recipient, or subrecipient — regardless of award size or aggregate award value — to promptly disclose in writing to the federal awarding agency, its Office of Inspector General, and any pass-through entity, any credible evidence of a violation of federal criminal law involving fraud, bribery, conflict of interest, or a gratuity violation under Title 18 U.S.C., or a civil False Claims Act violation, in connection with the award. This duty is triggered by the nature of the evidence, not by a dollar threshold on total award value, and non-compliance can itself trigger remedies under 2 CFR 200.339 (withholding funds, suspension, or termination). The two disclosure duties often get merged in institutional policy language; they have different triggers and should be tracked separately.
Suspension and debarment: what they are and how they differ
Suspension and debarment are the government-wide exclusion mechanisms that sit underneath FAPIIS. Both are administered under the nonprocurement rules at 2 CFR Part 180 (with a parallel, reciprocal procurement-side system under FAR Subpart 9.4):
- Suspension is a temporary exclusion, imposed immediately, pending completion of an investigation or legal proceeding, when there is adequate evidence of a cause for debarment. It’s a protective, interim measure, not a final determination of wrongdoing.
- Debarment is a formal exclusion for a defined period (commonly up to three years, though it varies by cause and can be extended) imposed only after the excluded party has had notice and an opportunity to respond — it follows a determination, not just an allegation.
Critically, exclusion under either the FAR system or 2 CFR Part 180 is reciprocal: an entity excluded under one blocks it from “covered transactions” government-wide, across both procurement and nonprocurement award types, not just with the agency that imposed the exclusion.
A “covered transaction” under 2 CFR 180.200/180.220 includes the primary award itself and lower-tier transactions such as a subaward, or a procurement contract awarded under a grant that is expected to equal or exceed $25,000 (any contract requiring the federal agency’s consent, or one for federally required audit services, is covered regardless of dollar amount). See CASRAI’s dictionary entry on debarment and suspension verification via SAM.gov for the full mechanics of the three permitted verification methods under 2 CFR 180.300.
Checking SAM.gov exclusions before you subaward, subcontract, or purchase
In practice, a research institution’s exclusion-screening obligation shows up at several points in the life of an award, not just once at the start:
- Before issuing a subaward to another institution or organization.
- Before entering a procurement contract (equipment purchase, consulting agreement, service contract) at or above the $25,000 covered-transaction threshold, or any lower-tier contract the prime award specifically extends coverage to.
- Before adding a new consultant, subrecipient, or key personnel to an existing award, where institutional policy reasonably extends screening to individuals as well as organizations.
- Periodically during the award period, since an entity’s exclusion status can change after the initial check — a one-time screening at proposal stage is not sufficient for a multi-year award.
Screening is done against the SAM.gov Exclusions database, maintained by the General Services Administration, which absorbed the older Excluded Parties List System (EPLS) when GSA consolidated it into the System for Award Management. See CASRAI’s guide to SAM.gov registration and the Unique Entity Identifier for the registration side of the same system.
Build America, Buy America Act (BABA): when it actually applies to a research institution
BABA was enacted as part of the Infrastructure Investment and Jobs Act (Public Law 117-58, 2021) and implemented government-wide through 2 CFR Part 184 (“Buy America Preferences for Infrastructure Projects”), effective August 23, 2023. Where it applies, BABA requires that:
- All iron and steel manufacturing processes occur in the United States.
- Manufactured products meet a domestic-content cost threshold for their components.
- Construction materials are manufactured in the United States.
for projects that federal financial assistance funds for infrastructure. Waivers (public-interest, nonavailability, or unreasonable-cost — commonly evaluated against roughly a 25% cost-increase benchmark) are available and agency-specific, and several federal research funders have issued general applicability determinations narrowing where BABA actually reaches within their own award portfolios.
The relief most research institutions rely on: BABA attaches to federal financial assistance whose primary purpose is infrastructure — construction, alteration, or repair of public infrastructure such as buildings, facilities, and related systems. A standard operating research grant or cooperative agreement that merely purchases lab equipment or covers salaries is not, by itself, an infrastructure award. Where research institutions actually encounter BABA is federally funded facility construction or major renovation — for example, an NSF major research-instrumentation or facilities award, or an NIH extramural research-facilities construction grant (C06/G20-type mechanisms) — where the sponsored-programs and facilities/capital-projects offices, not individual PIs, need to confirm domestic-content compliance and waiver status before construction contracts are let.
Section 889: the covered-telecommunications-equipment ban
Section 889 of the FY2019 National Defense Authorization Act (Public Law 115-232) prohibits federal agencies, and by extension federal contractors and grant recipients, from procuring or using “covered telecommunications equipment or services” from five named manufacturers — Huawei, ZTE, Hytera, Hikvision, and Dahua — and their subsidiaries and affiliates, as a substantial or essential component of any system, or as critical technology of any system. On the procurement side this is implemented through FAR 52.204-25 (and the related certification/reporting clauses FAR 52.204-24 and 52.204-26); on the grants side, the equivalent prohibition runs through 2 CFR 200.216. See CASRAI’s dictionary entry on Section 889 for the full definitional detail.
What this means for lab and facilities procurement in practice: Hikvision and Dahua are common, budget-friendly brands behind a large share of the security cameras and video-surveillance systems sold in the US, and Huawei/ZTE/Hytera equipment shows up in networking and radio gear. A purchasing office buying a building-access camera system, a networked badge reader, or telecom/radio equipment with grant funds — or installing it in space where grant-funded work is performed — needs to screen the vendor and underlying hardware manufacturer against the covered list, not just the invoice line item’s brand name on the surface. Many federal award applications and annual certifications now ask the institution to affirmatively represent it does not use covered equipment as a substantial or essential component of any system; getting that representation wrong is itself a compliance exposure independent of the underlying purchase.
Requirement-to-applicability map
| Requirement | Legal basis | Who acts | When a research institution is actually subject to it |
|---|---|---|---|
| FAPIIS agency review before award | 2 CFR 200.206 | Federal awarding agency | Whenever the federal share exceeds the simplified acquisition threshold — institution has no action, but should expect the review |
| FAPIIS recipient self-disclosure | Appendix XII to 2 CFR Part 200 | Recipient institution, via SAM.gov, semiannually | Only once total active federal grants/cooperative agreements/contracts exceed $10,000,000 institution-wide |
| Credible-evidence fraud/FCA disclosure | 2 CFR 200.113 | Applicant, recipient, or subrecipient, any size | Any time credible evidence of the specific listed federal crimes or a False Claims Act violation arises in connection with an award — no dollar threshold |
| Suspension / debarment exclusion | 2 CFR Part 180 (nonprocurement); FAR Subpart 9.4 (procurement, reciprocal) | Federal government (imposes); institution (screens for) | Institution must screen before any covered transaction — the primary award, a subaward, or a procurement contract at/above $25,000 |
| SAM.gov exclusions check | 2 CFR 180.300 | Institution (prime recipient or pass-through entity) | Before subawarding, before a covered procurement contract, and periodically through the award period |
| Build America, Buy America (BABA) | Pub. L. 117-58; 2 CFR Part 184 | Institution’s sponsored-programs/facilities offices | Only when the federal financial assistance’s primary purpose is infrastructure (construction/renovation) — not standard research operating grants |
| Section 889 telecom/video-surveillance ban | Pub. L. 115-232 Sec. 889; FAR 52.204-25 (procurement); 2 CFR 200.216 (grants) | Institution’s procurement/IT/facilities offices | Whenever grant funds purchase, or grant-funded work uses, covered equipment/services as a substantial/essential system component |
A pending change to watch: OMB’s proposed 2 CFR 200 rewrite
OMB published a proposed rule (Federal Register 2026-10817, May 29, 2026) that would substantially revise the Uniform Guidance and rebrand informal usage of Part 200 as the “Uniform Grants Regulation” — the formal “2 CFR Part 200” citation itself would not change. The public comment period closed July 13, 2026, and the proposal contemplates an October 1, 2026 effective date if finalized as proposed. As of this guide’s last verification date, it is still a proposed rule, not a final one — the FAPIIS, disclosure, and audit provisions described above reflect the currently effective text of 2 CFR 200. Institutions should watch for a final rule before assuming any of these thresholds or mechanics have changed.
Frequently asked questions
What is FAPIIS and who can see what’s in it?
FAPIIS is the government-wide system recording an awardee’s performance and integrity history. A limited public subset is visible to anyone via SAM.gov; the full non-public record is visible only to federal officials making award/responsibility determinations.
What actually triggers mandatory FAPIIS self-disclosure to SAM.gov?
Under Appendix XII to 2 CFR Part 200, once an institution’s total active federal grants, cooperative agreements, and procurement contracts exceed $10,000,000, it must semiannually disclose qualifying criminal, civil, and administrative proceedings from the preceding five years, or affirm nothing has changed.
What’s the real difference between suspension and debarment?
Suspension is an immediate, temporary exclusion pending investigation; debarment is a longer, formal exclusion imposed only after notice and an opportunity to respond. Either one blocks covered transactions government-wide, across both procurement and nonprocurement systems.
Do we have to check SAM.gov exclusions before every purchase?
Not every purchase — the covered-transaction threshold for a procurement contract awarded under a grant is generally $25,000, plus any contract requiring the agency’s consent or one for federally required audit services regardless of amount. Subawards are covered transactions regardless of size.
Does Build America, Buy America apply to a typical research grant?
Usually not. BABA attaches to federal financial assistance whose primary purpose is infrastructure — construction, alteration, or repair. Standard research operating grants that fund salaries, supplies, or equipment are not infrastructure awards by themselves; BABA mainly surfaces on federally funded facility construction or major renovation projects.
What does Section 889 actually stop us from buying with grant funds?
It bars using grant funds to obtain, or using as a substantial/essential system component, covered telecommunications and video-surveillance equipment or services from Huawei, ZTE, Hytera, Hikvision, Dahua, or their subsidiaries/affiliates — most commonly encountered in security-camera and networking procurement.
Is OMB’s proposed 2 CFR 200 rewrite going to change any of this?
Possibly, but as of this guide’s last-verified date it remains a proposed rule (FR 2026-10817), not final. The mechanics described here reflect currently effective regulatory text.
Last verified 2026-08-16 against 2 CFR 200.113, 200.206, and Appendix XII (via Cornell Law School’s Legal Information Institute eCFR mirror), 2 CFR Part 180, 2 CFR Part 184, FAR 52.204-25 (acquisition.gov), and Section 889 of Public Law 115-232. The status of OMB’s proposed 2 CFR 200 rewrite (FR 2026-10817) was confirmed as still-proposed via multiple converging law-firm regulatory-alert sources as of this date; re-verify if reading this significantly later.
