Have you ever stopped to consider the importance of the Contractor Performance Assessment Reporting System (CPARS) and how top management in both Government and Industry can use the evaluations to make strategic business decisions? The FAR requires CPARS evaluations but government auditors have reported that they’re not always done on time or with enough detail. So how can a busy Contracting Officer (CO) or Contracting Officer’s Representative (COR) move CPARS up their to-do list?
It starts with considering the value of CPARS evaluations, and working smarter so the needed information is documented along the way.
Why CPARS Matter
In my 35 years of Government service, I saw repeatedly that if the government customer was not happy, then the contractor was not happy. One of the most important aspects of the CPAR System is to ensure that assessments are an accurate depiction of a contractor’s performance. This is essential information to ensure government gets what it needs and contractors know whether and where they need to improve.
I also know that with the increase in workload among COs and CORs, filling out another report may not seem so important in the overall realm of things and may be put aside until the last moment and then hurriedly put together and submitted. “Whew, another piece of paper off my desk!” Well, CPARS reports are much more than just another piece of paper. They could influence whether an agency continues to fund an acquisition in the current year or support it for the next fiscal year, and could affect whether contractors will receive future consideration for work.
In a 2011 audit, the Office of Federal Procurement Policy (OFPP) stated there was a need to improve Contractor Past Performance Assessments. The report stated that:
- Eligible Contracts were not being registered in CPARS
- Performance Reports were not being entered in CPARS in a timely manner, and
- Narratives were of insufficient detail to show that ratings are credible and justified
The FAR in Part 42 states that agencies shall prepare an evaluation of Contractor Performance and submit it to CPARS; So what can be done to address the concerns of OFPP?
- COs and CORs must be diligent in ensuring that all contracts and/or purchase orders above the simplified acquisition threshold are registered in CPARS.
- Report performance at the end of the base year and each subsequent option year, and again at the end of the contract period. I find that a good reminder is to prepare and submit your CPARS ratings when making the determination to exercise the option and to prepare and submit your final report when you are doing your close out – make it a part of your package.
- Last, but not least, Agencies must ensure that their assessments are based on objective and measurable data and that it is supported by sufficient contract management data.
When writing CPARS evaluations, pay attention to the rating definitions “quality of product or service, schedule, cost controls, business relations, and utilization of small business (if the contractor is a large business). We understand that every contract is not going to run smoothly, there are going to be some bumps in the road, hopefully not many, but things happen on both sides (Government and Contractor). Just because you have had one bad day with the contractor, don’t get into what I call the “The Contractor DIDN’T Syndrome”, where every sentence starts with “The Contractor Didn’t”. Look at the CPARs definitions, then look at your surveillance reports and, other documentation and ALL of the circumstances surrounding each situation, then objectively speak to the situation and whether the contractors performed and how they performed and whether any issues were sufficiently resolved in a timely manner.
Writing the Narrative
Here are just a few points to consider when preparing to write the narrative:
- Address contract performance and be recent and relevant
- Be sure to collect input from the entire team (end-user, technical representative, site coordinator/program manager, etc.)
- Provide information that will demonstrate a complete understanding of the contractor’s performance
- Make sure there is a narrative for each rated element. (i.e. if there are elements entitled: Reporting, Project Management, etc., there should be a rating for each of these elements)
- Address any changes (modifications) to contract made since prior report
- Recognize any risks inherent in the effort and any role the Government may play in the Contractor’s inability to meet the requirements
- Indicate major/minor strengths and/or weaknesses
- Communicate throughout the process with the Contractor as well as your Government team.
- Document, Document, Document – Perhaps create a template or use some electronic tracking system to input information as it happens. If your documentation is current and consistent, writing your report will be a breeze.
Ask yourself if the Contractor’s performance was consistent with the program metrics and contract requirements. Have you documented all problems and solutions? Be clear and concise in stating what the contractor did to resolve any issues and whether the solution was effective and timely. As an example: “Due to weather conditions the contractor was unable to travel to perform the required work; however when conditions improved, the contractor doubled his staff in order to meet the deliverable date at no additional cost to the government.” This would be a clear indication of how the contractor performed under adversity.
Remember, narratives are the most important part of the evaluation; after you have written your narrative, re-read it. It is always good to have another set of eyes take a look at the report to ensure that your statements are non-personal and objective.
Providing accurate and complete evaluations can be a tremendous asset to Government in ensuring that contractors being considered for potential award are providing quality products and services and that tax payers are getting the best bang for the dollars spent. Many Contracting Officers are now making past performance an evaluation factor, which makes the narrative even more critical.
When Contractors and Government Teams work together, communicate effectively, and are aware of expectations on both sides, writing a high-quality CPARS report should be quick, allowing the writer to get back to their day-to-day activities much faster. “Work Smarter – Not Harder”