Contractor Past Performance Information - Improvements Needed

Today we conclude our short series on past performance assessments. In theory, the Government prepares past performance assessments on completed contracts. These assessments are crucial to the integrity of the past performance system. Contracting officers and source selection officials rely on current information on contractors' performance when determining responsibility and deciding to award new contracts. The quality of these assessments is also important in providing useful and meaningful information to source selection officials.

Last January, the Office of Federal Procurement Policy (OFPP) issued a report that was highly critical of the compliance rate (number of reports submitted versus the number of reports that should have been submitted) and also the quality of the reports submitted. To assess quality, OFPP evaluated 700 past performance reports from ten agencies to determine how well the four required rating factors were addressed. These four factors include;

• Quality of the product or service,
• Ability to control cost
• Ability to meet schedule
• Quality of business relations (e.g. customer satisfaction)

OFPP found that the reports generally lacked sufficient information to support the ratings. For example, most assessments did not include details about how the contractor exceeded expectations or corrected poor performance. Additionally, many of the assessments did not include ratings for one or more of the four performance areas. For one agency, the adequacy rate was only six percent. The best agency achieved only a 63 percent adequacy rate.

The OFPP report has already had an impact. DoD for example is strengthening its guidance and management controls to improve the collection of useful and timely past performance information. It is also increasing oversight to monitor both compliance and quality.

Now that the Government is beginning to emphasize compliance, completeness, and quality, significantly more contractor performance information is going to be crafted and dumped into a government database. More data means a higher likelihood that incorrect information (and potentially damaging information) will become part of the official source selection information. To minimize the likelihood that incorrect or incomplete data will affect your contracting future, we offer the following guidance:

• Always check any CPAR evaluation to ensure that it is a “proper and just” rating and that it reflects your actual performance.
• If you believe the rating is inaccurate, object in writing to the contracting officer and specify the areas that you believe are inaccurate and what the ratings should be.
• If you are not satisfied with the action taken by the contracting officer, always appeal to the proper authorities above the contracting officer. 

Remember that one inaccurate bad rating can jeopardize your entire contracting future.