The DoD, Office of Inspector General (IG) recently published its capstone report on DoD compliance with PAR regulations. Over a number of years, it reviewed 238 PARs prepared by Army, Navy, Air Force and Defense organizations. While the IG found that officials generally registered (or had valid reasons for not registering) contracts and prepared corresponding PARs, they did not consistently comply with preparation requirements. Besides the fact that a third of them were prepared an average of 73 days late, 200 of the 238 PARS were deficient in terms of complying with FAR regulations and the CPARS Guide. Specifically, DoD officials did not:
- prepare written narratives sufficient to justify the ratings given
- rate required evaluation factors, and
- prepare sufficient contract effort descriptions.
The IG found reasons for these deficiencies. They included
- assessors were not adequately trained and organizations lacked effective procedures for timeliness and reviews of the PARs (there it is, the "more training" recommendation - you see this in every IG report)
- there was a lack of internal controls within CPARS - no system requirement to write a narrative and insufficient explanations for the different ratings,
- the CPARS guide did not contain sufficient information related to the utilization of small business.
Now the big "so what". Why should contractor's care about these deficiencies? Well, without access to timely, accurate, and complete past performance assessment information, contracting officers will not have past performance information needed to make informed decisions related to contract awards. This could work against contractors whose good work on prior contracts are not considered in the selection process. We would also suggest that it could work against the Government as well if past poor performance was not documented.
As recommendations, the IG recommended more guidance, more training, and enhancements to CPARS that will require written narrative along with other information.
You can read the entire IG report here.