Monday, February 6, 2017

DoD Fails to Issue Adequate or Timely Appraisals of Contractor Performance

The Federal Acquisition Regulation (FAR) requires Government officials to evaluate contractor performance in the Contractor Performance Assessment Reporting System (CPARS) (see FAR Part 42.15). CPARS is the Government-wide reporting tool for past performance on contracts. The primary purpose of CPARS is to ensure that current, complete, and accurate information on contractor performance is available for use in procurement source selections. Government officials evaluate contractors in CPARS by preparing a PAR (Performance Assessment Report). PARs are to be prepared at least annually and at the end of the contract.

Most Government contractors are familiar with the PAR process and everyone strives for good reports. However, as many contractors have experienced, the Government often neglects to prepare PARs. That could be a good thing in some cases if you're the contractor and your performance has been less than stellar. Conversely, if your performance has been outstanding and the Government fails to put that in a report, that performance will not be recognized the next time you submit a bid and the contracting officer queries his past performance database to see how well you performed in the past.

The Department of Defense Office of Inspector General (DoD-IG) was concerned about contracting officer compliance with FAR 42.15 so they initiated an audit to see if there truly was a systematic problem. The results were not encouraging. The IG reported, in their typical understated tone, that "Defense organization officials did not consistently comply with requirements for assessing contractor performance". Translation? There was a high failure rate. Fourty-nine of 53 PARs reviewed did not include sufficient written narrative to justify the ratings given.

The DoD-IG cited several conditions that led to the failures:

  1. organization-specific procedures did not have clear guidance for preparing PARs in a timely manner or did not address timeliness
  2. assessors did not understand PAR rating definitions or evaluation factors
  3. assessors did not take current training or properly implement training and
  4. organization-specific procedures did not require reviews of PARs to ensure compliance with the FAR.

Because of the noted deficiencies, the DoD-IG concluded that Federal source selection officials did not have access to timely, accurate, and complete past performance assessment information needed to make informed decisions related to contract awards.

You can read the entire DoD-IG report here.

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