In the process of selecting contractors, the FAR (Federal Acquisition Regulations) require agencies to consider past performance as a factor in competitive procurements exceeding the simplified acquisition threshold (currently $150 thousand). That makes sense. Why would the Government want to award contracts to companies that don't perform? Contracting officers have more work than they can do right now - why add to the burden with contracting issues that just chew up time. Of course, to be in a position to "consider" past performance, contracting officers need relevant past performance data. FAR provides for that by requiring agencies to evaluate contractor performance at least yearly and also, at the time the work is completed. That requirement is well and good but years ago, the GAO found that very few agencies were bothering to write up past performance reports and even those few that were written up, were dropped off in some dead letter office never to be seen again.
In 2004, the DoD developed and began using CPARS (Contractor Performance Assessment Reporting System) and by 2010, all Government agencies were tied into the system. In theory, a contracting officer from NASA could review past performance data from a prospective contractor who worked for DoD or Energy, or any other agency. The centralized database was a good idea, however several GAO (Government Accountability Office) reviews determined that there was still a low compliance rate in writing up past performance information and therefore, incomplete past performance information loaded up into the CPARS.
The 2013 NDAA (National Defense Authorization Act) included a requirement to develop a strategy to ensure that evaluations in past performance databases. In response to this requirement, the Government established some strategies to improve compliance including (i) increase emphasis through memos to agency officials, (ii) self-assessing compliance, (iii) more training, (iv) setting performance targets, and (v) developing content guidelines. The last strategy was considered high risk because with the increased emphasis on past performance evaluations and the push on contracting officers to complete them, the quality of those evaluations suffered considerably. Some evaluations were simply check boxes where contractors were rated highly and no narrative accompanied the score. Some contracting officers simply doled out the highest score possible because (i) they either had no information to the contrary or (ii) they didn't want to deal with the inevitable contractor disagreement process that would ensue for any evaluation less than perfect.
Last week, the GAO issued a report that assessed agency compliance with the CPARS reporting requirement. Notably, the study did not assess the completeness, timeliness, or accuracy of those evaluations - only whether the evaluations were uploaded into CPARS. Overall, Government agencies are making improvements in complying with the past performance requirements. Overall, the compliance rate for the year ended April 2014 was 49 percent. Although not great, it represents a significant increase over the 32 percent from the previous year. DoD is doing the best at 83 percent compliance. GSA had the lowest compliance rate at 13 percent.
You can read the entire GAO report here.
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