The past is something that is impossible to escape. That is especially true when it comes to how well a contractor fulfills its mission for the federal government. The Contractor Performance Assessment Reporting System (CPARS) is a web-enabled application system that collects and manages the records of a contractor’s performance – and its a critical tool in establishing who the government does business with.
In January, CPARS officially replaced the Past Performance Information Retrieval Systems (PPIRS), which was retired. The two systems were merged together with CPARS becoming the official system for past performance information.
Each assessment is based on objective facts and supported by program and contract management data. This can include cost performance reports, customer comments, quality reviews, technical interchange meetings, financial solvency assessments, construction/production management reviews, contractor operations reviews, functional performance evaluations and earned contract incentives. As such, this can include both the positive as well as negative results of a contractor during a specific amount of time.
CPARS is for unclassified information only, and classified information is not to be entered into the system.
The performance evaluations contain both government and contractor comments as a way to also provide a balanced view of performance, and this is meant to allow source selection officials to look beyond just contractor references.
In addition, integrity records could contain federal contractor criminal, civil, and administrative proceedings in connection with federal awards; suspensions and debarments; administrative agreements issued in lieu of suspension or debarment; non-responsibility determinations; terminations for cause or default; defective pricing determinations; termination for material failure to comply; subcontractor payment issues; information on trafficking in persons; and recipient not qualified determinations.
CPARS offers detailed information, but by some accounts the interface is cumbersome. A current complaint is that while CPARS was meant to simplify functions such as creating and editing performance and integrity records or viewing/managing of those records – it has been anything but simple.
The process is inherently individualistic, and requires the input of multiple stakeholders involved in the clearance award and management process in order to be useful. Agencies must also justify the award ratings they provide – where agencies fail to take the time to provide information, performance ratings could be left inaccurate, which in turn diminishes the value of CPARS.
Despite critics, many contractors do see a benefit in CPARS, and say the system is generally accurate.
“Most COs are willing to work with us to make sure that our input is included to clarify things if needed to represent accurate past performance (PP),” explained Brendan Walsh, SVP partner relations and Don Hirsch, SVP of service delivery at The 1901 Group.
“Overall PP is a reasonable measure for the government to use; however, CPARS are only a single data point for measuring capabilities,” noted Walsh in an email to ClearanceJobs. “Companies may have additional capabilities that are not reflected in CPARS or PP, so PP’s should not be the only factor used in deciding what a company can do or how it will perform.”
Past performance predicting contractor future?
Past performance information has been considered relevant information for the future source selection purposes. This is because it includes a contractor’s record of conforming to requirements and standards of good workmanship as well as commitment to the interests of the customer.
Thus government officials are encouraged to objectively evaluate the performance of contractors, and review relevant performance and integrity information before making an award decision. Contractors can comment on the government’s evaluation and concur with or refute the performance evaluation. It should be noted that contractors may view only their own data.
There is a lot of data, but some have questioned whether the data is detailed or even accurate enough for those in the government to make an informed decision during the selection process. One issue comes back to justifying the ratings above or below “satisfactory.” With effort required to notate anything above or below the standard, more contractors could be getting a more generic “average” rating.
A May blog post by Alan Chvotkin, Professional Services Council executive vice president and counsel, addressed the entire process:
“With past performance being such an essential element of federal contracting, isn’t it in the government’s best interest to have timely and accurate contractor performance assessment reporting systems (CPARS) ratings and for contractors to ensure that they are recognized for their work? Now contractors have more control over their own ratings and how the Government uses those ratings.”
Chovotkin added, “Where you have strong past performance, you want the world to know it. But a less than stellar past performance rating does not have to be the prologue when competing for and performing future government contracts.”
One clear gap in CPARS is the lack of data for private sector past performance. This could mean that agencies lack the full picture when seeking non-traditional contractors.
While experts agree that overall CPARS is a good tool, with the right refinement and improvements including automation to help streamline the process it could be made better and more importantly simpler to use.
