Predecessor and Successor Details

A final rule was recently released on March 7, 2016, in regards to amending the FAR to implement a section of 2013 NDAA to include in FAPIIS information on the immediate owner or subsidiary and all predecessors of an offeror that held a federal contract or grant within the last 3 years. This facilitates the contracting officer in making a determination of responsibility by reviewing the performance and integrity information available in FAPIIS for a prospective offeror.

SAM.gov has recently been updated requiring federal contractors to answer questions in regards to their immediate entity owners, highest level owners, and now a new page titled “Predecessor Details” which requires federal contractors to answer whether their entity is a successor to a predecessor that held a federal contract or grant within the last 3 years.

Predecessor is defined as “an entity that is replaced by a successor and includes any predecessors of the predecessor.” Successor is defined as “an entity that has replaced a predecessor by acquiring the assets and carrying out the affairs of the predecessor under a new name (often through acquisition or merger). The term “successor” does not include new offices/divisions of the same company or a company that only changes its name.