This issue became a topic of discussion at a recent conference for the tool used to rate performance evaluations submitted by federal agencies; the Contractor Performance Assessment Reporting System (CPARS).
As reported by Federal Computer Week:
…CPARS past performance reports are critical to agencies, as well as to contracting companies. They document vendors’ performance on contracts previously awarded and completed, and federal agencies rely on the reports for market research for upcoming contracts. A mark below “exceptional” or “very good” on CPARS can mean the next agency passes on a vendor for its contract.
…Unfortunately, given smaller contracting staffing, increasing duties at agencies and federal policy that now requires agencies to explain why they give contractors higher ratings, CPARS scores are puddling in the “satisfactory” pool, according to [Professional Services Council President and CEO David Berteau]. A “satisfactory” rating is faint praise and can cost a vendor business, contractors at the event said…
This has become a vicious circle. Firstly, program offices need to be able to not only access CPARS, but also use it effectively to conduct market research. Further, Contracting Officers (COs) need to ensure that the program offices are effectively documenting contractor performance.
The FCW article only discusses the responsibilities of the CO, but fails to mention the integral stakeholder required to correct this deficiency; the Contracting Officer Representative (COR).
It is the COR who needs to document performance, and provide this information to the CO for documenting in CPARS.
The driving force needed for CPARS compliance is accountability:
…Katrina Brisbon, assistant administrator at the Transportation Security Administration’s office of contracting and procurement, said her agency measures how quickly and effectively contracting personnel complete reviews in CPARS as part of their job performance reviews. The agency also requires vendors to provide self-assessments of their performance.
The techniques, she said, have helped move the needle on CPARS reporting among contracting officers at her agency from 60% completion rates months ago to 90% now… [Emphasis added]
This is not surprising, and a great method to ensure CPARS be part of normal contract governance and oversight.
Further, having COs provide tools and instructions to the COR is also an oft-missed opportunity for compliance across many procurement organizations. Although contracts require a post-award contract meeting with the contractor (i.e. “Kickoff Meeting”), it is not common for the CO to conduct a Kickoff meeting with the COR.
This should be standard practice upon contract award, and as part of the COR Appointment Letter materials. The CO should set expectations for contractor evaluations, provide the templates or the required documentation for easy upload and integration into CPARS, and the frequency of evaluations.
Most importantly, the COR needs to be held accountable, just like the CO, to ensure that performance reporting is not arbitrary, and with meaningful purpose.
I also like the idea of contractor self-assessments, which provides the contractor the opportunity to discuss how they believe they are performing, and close any gaps and bring to light any differences in perception or actual performance. In theory, there should not be any if the COR and the CO are both properly monitoring the contract.
A great resource that Defense uses is the Contracting Officer’s COR Review Checklist. This is a great document that ensures the CO and COR are coordinated, expectations are met, and all the correct procedures are executed for assigning the COR and verifying effective contract administration and documentation.
CPARS needs to be a powerful resource for effective accountability for performance. This starts with ensuring accountability is at the forefront of procurement personnel. Unless this changes, we can expect “Satisfactory” to be the standard.