Recently, the Federal Acquisition Regulations (FAR) was amended to better track corporate performance of affiliated companies. In short, this is rule is likely designed to combat entities that had issues performing federal contracts and reformed or reconstituted themselves or affiliated companies to avoid the consequences of those issues. This is going to primarily effect FAR Part 9 and 52 by amendment.
Introduction from Federal Register
On May 7, 2016, a final rule was issued, effective April 2016, that amended the FAR to implement a section of the National Defense Authorization Act (NDAA) for Fiscal Year 2013 to include in the Federal Awardee Performance and Integrity Information System (FAPIIS), to the extent practicable, identification of any immediate owner or subsidiary, and all predecessors of an offeror that held a Federal contract or gran within the last three years. The objective is to provide a more comprehensive understanding of the performance and integrity of the corporation before awarding a Federal contract.
Summary from the Federal Register
DoD, GSA, and NASA are issuing a final rule amending the FAR to implement section 852 of the National Defense Authorization Act (NDAA) for Fiscal Year FY2013 to include in FAPIIS, to the extent practicable, identification of any immediate owner or subsidiary, and all predecessors of an offeror that held a Federal contract or grant within the last three years. The objective is to provide a more comprehensive understanding of the performance and integrity of the corporation before awarding a Federal contract.
If you are operating under the small business rules of the SBA, this may not affect you as greatly because of the definitions used in those programs. The one twist that may occur is if a holding company is active in government contracting and the owner of another government contracting firm. If that is the case, you may want to examine the regulations a bit more closely.
