Tuesday, May 1, 2012

Past Performance - Again

When awarding contracts, FAR (Federal Acquisition Regulations) require agencies to consider firms' past performance records to help ensure that taxpayer dollars go to capable contractors. Past performance is not to be confused with prior experience. Prior experience refers to whether the firms have done similar work before, and past performance describes how well they have done that work.

While agencies have long been required to prepare a performance report at the conclusion of each contract, compliance with the requirement has always been problematical. Even when, in the relatively few cases where performance reviews were prepared, there was no central repository for these reports, making it impractical for contracting officers to consult past performance when contemplating the awards of new contracts.

The 2012 NDAA (National Defense Authorization Act) attempted to bring some structure to the program. It required DoD to develop a strategy for ensuring that timely, accurate, and complete information on contractor performance is included in past performance databases used for making source selection decisions, including standards for the timeliness and completeness of submissions and assigning responsibility and management accountability for the completeness of submissions.

For contractors, its important that past performance data be prepared timely and made available for contractor selection and award purposes - especially for ratings of "exceptional" or "very good". (Exceptional means that performance meets contractual requirements and exceeds many to the Government's benefit).

So, how is the Government doing? What is the Government's report card? Not too good, unfortunately. DoD just released its second quarterly report on past performance reporting. It didn't even hit 50 percent. For the three months ended March 30th, 2012, DoD prepared past performance reports for only 47 percent of completed contracts. This is actually worse than the previous three month period when the compliance rate was 59 percent.

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