Standardizing Past Performance Ratings

The FAR Councils have published a proposed rule that will provide Government-wide standardized past performance revaluation factors and performance ratings and to require all past performance information be entered into a centralized database (CPARS - Contractor Performance Assessment Reporting System). We've written in the past about past performance ratings and the various rating factors. Some agencies have been serious about them while others, not so much. Under the proposed rule, all federal agencies will standardize under common rating factors and their compliance with these requirements will be assessed on an annual basis. The government is getting serious about keeping the "bad guys" out of the contracting business.

Inputs into past performance ratings come from the technical office, the contracting office, and where appropriate, the end users of the product or service. Evaluations must reflect how the contractor performed. The report must include clear relevant information that accurately depicts the contractor's performance, and be based on objective facts supported by program and contract performance data. The evaluations should be tailored to the contract type, size, content, and complexity of contractual requirements.

Evaluation factors for each assessment must include, at a minimum, the following:

• Technical or quality
• Cost control
• Schedule/timeliness
• Management or business relations
• Small business subcontracting

Each of these factors must be rated on a scale of one to five; exceptional, very good, satisfactory, marginal, and unsatisfactory. Once entered into the system, it stays for three years and is available for agencies to utilize.

Comments from interested parties must be received by the FAR Council by August 29, 2011 to be considered in the final rule.