An essential element of most proposals submitted in response to a solicitation is the Past Performance evaluation factor. FAR Part 42.15 – Contractor Performance Information requires that contractor performance information be collected and maintained by federal agencies. This information is used to evaluate past performance of an offeror as described in a solicitation in accordance with FAR Part 15, in order to establish a confidence rating. GovContractPros (“GCP”) encourages our clients to be an active and informed participant regarding their Past Performance evaluations.
Past performance of contractors must be evaluated on an annual basis for contracts which exceed the simplified acquisition threshold. The Past Performance evaluation process is typically initiated by the government within thirty (30) days of contract award, when the government inputs the contract record the Contractor Performance Assessment Reporting System (“CPARS”). Contractors should be sure to assign “Contractor Representative” in CPARS as soon as practicable and ensure that an officer or employee is monitoring CPARS so long as you are performing contracts valued in excess of the simplified acquisition threshold. With regard to the “annual evaluation,” typically this event coincides with the exercise of option years, though in GCP’s experience, these ratings of sometimes delayed beyond the exercise of an option.
Contractors should know that Past Performance ratings are required for each contract valued above the simplified acquisition threshold. In practice, this means that on indefinite delivery-indefinite quantity contracts (“IDIQ”) or blanket purchase agreements (“BPA”), each task order, delivery order or call valued above the simplified acquisition threshold must be rated. These ratings are not given at the IDIQ or BPA level. Recognizing that you may be performing multiple task orders or calls under a single IDIQ or BPA, it is critical to ensure that each evaluation is carefully scrutinized to determine whether or not you will provide comments in CPARS for the assessment. The CPARS evaluation includes an assessment of the following performance areas:
- Cost Control
- Management or business relations
- Small Business Subcontracting
- Regulatory Compliance
GCP encourages all federal contractors carefully to review these assessment areas for concurrence or non-concurrence. In our next Blog Post, GCP will explain the process for Past Performance ratings disputes and assessing adjectival ratings, but if you would like to receive advice or a review by GCP of agency Past Performance ratings, or have questions about Past Performance ratings, please contact us.