Making Past Performance Matter: Effective Use of CPARS

The American Council for Technology (ACT) and Industry Advisory Council (IAC), in conjunction with GovConRx, LLC, recently released a report on industry viewpoints in regards to past performance data and the Contractor Performance Assessment Reporting System (CPARS).

The abstract report described on the ACT-IAC website:

“The Office of Federal Procurement Policy (OFPP) has an initiative to modernize the collection and use of contractor past performance information by improving the effectiveness and efficiency of policies, strategies, tools, and learning aides supporting the collection of information on contractor performance. GovConRx supported this initiative by implementing a series of industry forums, meetings, and surveys to gather industry perspective and other evidence-based information to improve the past performance processes. GovConRx engaged with four major industry associations; Professional Services Council (PSC), Armed Forces Communications and Electronics Association (AFCEA), American Council for Technology and Industry Advisory Council (ACT-IAC), and the Government Technology and Services Council (GTSC).”

I have written about these issues before (here and here). However, the constant criticism of formulaic, compliance-driven CPARS ratings does not seem to be abating. The standard process is to rate a firm Satisfactory, check boxes, and move on. Further, any real opportunity realistic ratings are not done due to the “hassle” of having vendors challenge ratings that they disagree with or they believe unfairly negative, not to mention ratings being done very late, or not at all.

At the annual CPARS rating, there should be no surprises, as both parties should have an understanding of what the official CPARS ratings will be for a vendor on a specific contract. Regretfully, this is usually not the case.

So how do we improve contract management communications?

From the report:

“Encourage Contractor Self Assessments – On overwhelming 95% of industry participants support the use of contractor self-assessments provided at agreed intervals throughout the contract performance period to promote more frequent government-contractor communication.”

I agree that self assessments could be helpful. If the contractor thinks everything is great, but the government thinks the contractor’s performance is subpar, why the disconnect? Most contracts require monthly status reports, or even weekly reports between the contractor and the Contracting Officer Representative (COR) and the Contracting Officer (CO). The contractor is working and communicating with the project manager (PM) probably on a daily basis. So with all this communication, how is it that CPARS ratings are always a difficult challenge? Is overall performance not being discussed? There are never challenges? Where is the documentation?

The report also describes simplifying CPARS ratings for less complex contracts that could hopefully improve quality, as discussed by former Office of Federal Procurement Policy Administrator and Federal Computer Week contributor Steve Kelman in several blog posts from The Lectern (here and here).

From the report:

“Implement a Simpler, Expedited “CPARS Lite” Reporting Option – Industry feedback shows that 84% support implementing a simplified CPARS process for certain fixed price and commercial item contracts and less complex procurements under a certain dollar value (e.g., $500,000). We refer to this as “CPARS Lite”. This would allow expedited CPARS ratings and reduce the burden of CPARS reporting across the Acquisition Workforce. This is especially true for those contracts where it would be unusual for a contractor to be rated more than satisfactory. CPARS Lite evaluations would have the same weight as regular CPARS evaluations in the source selection process, but would require far less inputs, include a single rating narrative block that would allow for only a brief narrative to explain any ratings above or below satisfactory.”

I really like this idea. If we create less of a burden to help streamline and expedite CPARS ratings for these situations, there is more of an opportunity and impetus to focus on quality, and less on compliance.

Past performance should be an important differentiator in selecting vendors for future government contracts. COs should be using CPARS ratings to vet contractors, as part of due diligence pre-award. Regretfully, often times ratings are missing, or do not provide enough information to gauge a sense of real performance since usually everyone is satisfactory, if the rating even exists.

The one thing really missing from this equation is accountability. Acquisition personnel, which include PMs, should have their contract management performance be part of their respective performance ratings, given the importance of the function to effective outcomes. It is part of the job, and an important one. So is it done well or not, or even at all? We can not rate what we don’t measure.

CORs should also not be doing CPARS ratings in a vacuum, which also happens more often than not. PMs should also be held accountable for performing the CPARS ratings, since they have the most relevant information. COs should be providing training to the COR and PM on CPARS, the process, why it is important, and how to create effective ratings.

Past performance ratings should be a powerful tool to incentivize better vendor performance. They need to be done right, and often.

Let’s create a culture of accountability and effectiveness. They go hand in hand.

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