Prime Contractors Called Upon to Release Subcontractor Past Performance Ratings

Past performance information is one indicator of an offeror's ability to successfully perform the contract and is often considered by agencies when making contract awards. While there is a mechanism to log and retrieve past performance information for prime contractors (e.g. Past Performance Information Retrieval System (PPIRS)), there is no comparable system to track past performance for information for subcontractors. That is about to change.

The SBA (Small Business Administration) is initiating a pilot program to establish past performance ratings for small business subcontractors. Under this program, a small business concern without a past performance rating as a prime contractor, may request a past performance rating if it is a first-tier subcontractor under a covered Government contract with a contractually required subcontracting plan (see FAR 19.702(a)).

Here's how it will work.

1. The small business concern submits a request to SBA for a past performance rating within 270 days after completing the work for which a past performance rating is sought. The application will include the subcontractor's "suggested ration". We can't imagine that any subcontractor would suggest a rating of anything less than "Exceptional".
2. The SBA will forward the request to the prime contractor and the contracting agency's Office of Small Business Utilization (OSDBU).
3. The prime contractor and the OSDBU will work together to agree on a rating and then post it into the Government's CPARS (Contractor Performance Assessment Reporting System).

The pilot program includes procedures to follow if there is disagreement at any level over the final rating.

This will be additional work for Prime Contractors who will now be called upon to make past performance information on their first-tier subcontractors readily available to the Government. Certainly, most prime contractors have information relative to subcontractor past performance in their records however its one thing to have the information available for internal use and quite another to make that information available to the Government. We expect that ratings for public consumption will be a lot less candid and informative than ratings used for internal purposes.

You can read more about SBA's pilot program here.