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formerfed

Serious Past Performance Evaluation

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I'm convinced the government's past performance process needs a major overhaul. In theory, it's a good concept. In practice, it's often useless. Just looks at CPARS reports and it's rare to find a bad rating. I've heard many COs say they and program managers don't tell the complete truth because it's too difficult dealing with repercussions.

Now here's some refreshing way to address poor contract performance. This is a Steve Kelman commentary on GSA's lease of the Old Post Office Building in Washington DC.

http://fcw.com/blogs/lectern/2014/06/trump-develops-old-post-office.aspx

This is one key part of his blog

A third thing that caught my eye was Trump's confident statement the building would be ready for guests in time for the 2017 inauguration. Here my observation was less flattering to government. Almost 20 years ago, New York City handed over renovation of an iconic skating rink in Central Park to Trump after various delays in the city's own procurement process. It was noted at the time that Trump had a powerful weapon to keep the contractors he hired on schedule -- the threat to cut them off from other business his empire did with them.

Today the federal procurement process works better than in the past, and it is conceivable a government-managed procurement could also meet this 2017 deadline. But I wouldn't bet the farm on it. Government needs to learn that it too is a big customer, and it too should use its clout more aggressively than it does to get contractors to perform well.

It would be interesting to hear the government tell a contractor at the start of a project that delays and other performance problems will be severly critiqued and extensive detailed in the report. So bad performance will be widely published and not dismissed in a brief paragraph with a satisfactory rating.

What do you think?

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Today the federal procurement process works better than in the past....

Really? That's a pretty broad, vague generalization, and it seems to fly in the face of some well-publicized recent events. What are the criteria? What is the evidence? What were the measurements? What was the reasoning? Everything else Steve said in that blog post is hooey until he clarifies and substantiates that assertion.

You have to understand that Steve is a rah-rah kind of commentator. He likes to tell "success stories" and say good things, which is fine, but which means that you cannot take him seriously as a critic or scholar based on his blog. Also, there is no follow-up in his blogs. Steve teaches in the Kennedy School, not the Harvard Business School. The whole thrust of the blog post was to congratulate GSA for giving Trump a contract. Trump hasn't succeeded at anything yet. Has has failed to succeed on several occasions.

Here is Time magazine's 2013 list of Trump's top ten development failures:

http://content.time.com/time/specials/packages/completelist/0,29569,2068227,00.html.

Here are some other links to stories in 2013 of Trump failures:

http://www.independent.co.uk/news/uk/home-news/donald-trump-fails-to-deliver-on-golf-resort-jobs-pledge-8693854.html

http://www.businessinsider.com/whats-the-first-image-that-pops-into-your-head-when-you-think-of-donald-trump-2013-8

http://www.rollingstone.com/politics/pictures/the-many-business-failures-of-donald-trump-20110511

So, why did GSA give Trump the contract? Let's hope that GSA's "dynamic" leader, as Steve calls him, doesn't end up looking like a bad decision maker.

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I'm convinced the government's past performance process needs a major overhaul. In theory, it's a good concept. In practice, it's often useless. Just looks at CPARS reports and it's rare to find a bad rating. I've heard many COs say they and program managers don't tell the complete truth because it's too difficult dealing with repercussions.

...

What do you think?

I have a background in auditing. In college I had an assignment to look for an "adverse opinion" or a "qualified opinion". It was a lot harder than I thought it would be. My experience is that auditing is more of an engine governor than a speed limit. The client negotiates with the auditor about what is too risky.

I am not sure of how my experience in auditing applies to past performance ratings in the government. The government may think a contractor could not be replaced fast enough. Auditors may also be concerned with a client leaving (unless more concerned about being sued). I hope the analogies help.

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The way most agencies do past performance evaluation is just poor. To gather data, they start by asking offerors for a certain number of references. Then they usually send an email questionnaire to each reference. Finally they check the Governmentwide database of past performance evaluations.

The problems here are many starting with the question of what offeror would include a poor reference even when it be the most relevant and meaningful? Next it's very easy for a reference to reply to an email questionnaire and avoid making strong negative statements. Probably more pertinent, it's just easiest to ignore the email. Most procurements do well when a return rate of 40% happens. The government past performance database is filled with good reports and it’s rare to see anything that's clearly bad. If you ask agency program managers about CPARS assessments, they will say they avoid it when they can and also don’t say too many negative things. It’s rare when agencies take further steps and that's gather facts about performance on their own. Here's a perfect example

http://www.washingtonpost.com/politics/health-care-web-sites-lead-contractor-employs-executives-from-troubled-it-company/2013/11/15/6e107e2e-487a-11e3-a196-3544a03c2351_story.html

How could someone evaluate past performance and not note this? How many agency past performance evaluations even involve a simple Google search?

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formerfed:

Okay, let's discard requests for references. How would you go about evaluating past performance? What process would you use for a $20 million/year services acquisition in which you expect to receive up to 10 proposals from both large and small businesses and in which 40 percent of the work will be subcontracted?

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Prediction: In the future, all source selection decisions will be recommended by computer. The computer will 1) search the internet for bad things about the contractor; 2) see how many "buzz" words were in the contractor's technical approach; then 3) conduct a trade-off using an algorithm based on price and technical factors. It probably would pick better contractors than at least a few COs.

The biggest problem with past performance is that it is too cumbersome to properly report. Soliciting agencies want a book report on how great/horrible the Offeror is at performing their requirement. Responding agencies have better things to do, like doing their FAITAS report, and prefer just to check some boxes without the Offeror yelling at them. CPARS wants check boxes and a book report at least once a year per contract. The regs require agencies to verify they are timely completing the CPARS, something that no one wants to do. For a good laugh about what this system creates, see B-408248.6 (http://www.wifcon.com/cgen/408248.pdf). Yes, it is anecdotal, but it supports my point.

Past performance needs to become less personal and easier to complete. Take a look at how past performance works in the commercial marketplace. It is all anonymous, publicly available, and with very little censorship. Customers on eBay and Amazon can rate Vendors relatively anonymously and say what ever they want. If you have ever looked at CPARS, it is not user friendly and looks like something out of the 1980's. The guidance from OFPP is to create a lengthy narrative explaining the rationale, but then gives the contractor the right to rebut the information.

In my opinion, agencies should be able to say things anonymously and with as little or much detail as they want, and on an easy to use tool. There should be more metrics that agencies can rate the contractor so that each contractor can have a dashboard for certain performance areas. Then compu... I mean Contracting Officers can use those metrics in their award decision.

Until past performance becomes anonymous and easy to report, it will never be an accurate representation of contractor performance.

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Vern,

I would start with online searches. The focus is on finding performance issues and any possible related work to my action, both private and public sector. Then I would check FPDS and find any related contracts. I think would start calling people and ask questions about the offeror, including what other customers they are aware of. All this takes time and effort but if past performance was a significant part of the evaluation, it would be worth it.

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formerfed:

So you would search online for information of some kind. You would also search FPDS to come up with a list of contracts.

I have some requests and questions:

1. Please give us some examples of your online searches. What words or phrases would you type in a Google search box?

2. Please give us some examples of some of the questions you would ask about an offeror.

3. Are there any specific databases you would search?

4. Once you got information, how would you process it?

5. What would you look for in the information?

6. What specific conclusions would you seek to reach?

7. How would you present your conclusions to the SSA? As ratings? As expository reports? As a combination?

8. If you would use ratings, what kind of rating scheme would you use? What kind of scale would you use?

9. Would you bother looking for commercial contracts? Would you look for contracts with state and local governments, which would not be listed in FPDS? If you would look for commercial and state and local government contracts, where would you look?

10. Finally, please recommend any sources of information you know about that describe how to research company history and performance.

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I would just start searching with the offerors name and take it from there. The objective is finding other relevant experiences whether it be government, commercial, or even overseas. Once I found that information and contacts the questions aren't much different from what are typically asked - what is the size and relevance of the work, what are your experiences with this source, did they come in within budget, what problems did they experience and how were they resolved, etc.

The information gets evaluated and reported in the typical manner whether it's strenghts, weaknesses, risks, etc.

What I'm getting at is just digging into all sources for information and not just using the offeror provided references or what is in CPARS.

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I forgot to mention all the information available that isn't dervived from questionning. Many sources in specific industry segments are rated through independent means. For example in the IT field companys like Garnder considate customer experiences and publish rankings using various criteria. Also awards and recognition can provide meaningful information on a particular companies ability to sucessfully perform. I would include that data as well.

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formerfed:

I know what you're getting at, but the problem is much bigger than just searching for an offeror's name.

What information are we looking for? How are we supposed to -- and are permitted to -- credit and use the information we find? What, if any, standards of evidence should we apply? What kinds of conclusions should we be trying to reach? If there are sequences of conclusions, how to we work from first to last? When asking questions about an offeror, what kinds of questions should we ask? Should we use marketing techniques, like Likert scales, in order to standardize responses and facilitate statistical analysis, or should we accept free-form answers and then try to sort them out? Those are just a few of the questions we could ask and answer if we want to improve the evaluation of past performance.

This is supposed to be a discussion board. If I had known that all you were doing was complaining about how badly the government used past performance, and didn't have any concrete ideas about how to make it better, I wouldn't have wasted time responding. Do you think people will do a better job just because you complained?

I am bored by answering the same basic questions over and over again for the same small set of the clueless. How many times are we going to get questions about the exercise of order options under GSA schedule contracts? Every now and then a good question comes up, but most are incoherent or elementary or have already been answered, and it shocks me that people have to come here for answers instead of just asking people in their offices or searching on the internet. And then we sometimes give crummy, un-referenced answers and even wrong answers.

The clueless will always be with us. But past performance is an interesting topic, and i was glad you raised it, because I thought we could have a fruitful discussion. But now I don't know why you bothered. Who cares that you think the government doesn't do a good job? What people care about (I hope) is how to do a better job. But all we get from you is this:

I would just start searching with the offerors name and take it from there. The objective is finding other relevant experiences whether it be government, commercial, or even overseas. Once I found that information and contacts the questions aren't much different from what are typically asked - what is the size and relevance of the work, what are your experiences with this source, did they come in within budget, what problems did they experience and how were they resolved, etc.

The information gets evaluated and reported in the typical manner whether it's strenghts, weaknesses, risks, etc.

What I'm getting at is just digging into all sources for information and not just using the offeror provided references or what is in CPARS.

Criminy! If we want to improve the use of past performance in source selection, that's not even the beginning of wisdom.

formerfed, I thought that if there was anyone with whom to have an intelligent discussion about an important topic, with whom to have a useful exchange of ideas, it would be you.

We made a mistake years ago by letting Wifcon Forum become a Q&A site, an unofficial Ask A Professor. But if that's all that people want (and I fear that it is), if that's all that we old-timers can do for the newbies (and I fear that it is), then have at it.

I'm signing off.

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Vern, before you take your FAR and go home, I wanted to present an alternative solution. The past performance system is completely broken. Every Federal agency is required to invest thousands of hours each year into the antiquated CPARS boondoggle. I feel especially bad for those agencies where every action exceeds $150k, because they need to follow FAR Section 42.1501 for just about every acquisition.

Back in January 21, 2011, OFPP issued a memorandum, “Improving Contractor Past Performance Assessments,” which to sum up its 9-pages (in my opinion) it asks for a book report if you give a Contractor anything other than satisfactory. Because of the amount of additional documentation, Government employees do not want to spend the time doing it. To make matters worse, the medium to which the information is entered is not just un-user friendly, but downright arduous to use and administer. The combination of the book report requirement and the poor reporting system implementation results in the opposite of what the OFPP memorandum intended.

The objective of past performance reporting is to create a repository for the satisfaction of a Contractor’s customers with sufficient details to allow a Contracting Officer to make a valid source selection decision. To create a successful past performance system, you need:

A) Participation from customers;

B ) Sufficient information to be meaningful;

C) User-friendly interface to view past performance from a macro to a micro-level; and

D) Anonymity.

Imagine for a second a past performance system from the future.

What the Reporting Agency Sees: You would log into your Contractor Performance System (CPS) dashboard, and see a list of your agencies current and active contracts.

Contract # Contractor Description Value Score Rating

ABC-14-0001 SneakyCorp Bio Remediation $25m ** Not Acceptable

ABC-14-0002 SallyCorp 1965 Mustangs $15m **** Acceptable

ABC-14-0003 Whodunnit Widget Repair $30k *** Acceptable

ABC-14-0004 Wascally Wabbits $45k - Needs Rating

The contract number, contractor, description, value, and other pertinent information (PSC, period of performance, about the contract are all automatically populated for each agency from FPDS-NG automatically. Agencies would no longer need to manually enter in contract information manually like CPARS.

In the above list, CPS would give the COR and the CO daily notifications to leave feedback for companies without an annual rating. If I were to click on my Wabbit contract with Wascally, I could optionally enter in comments, but would be required to at least rate my feedback for:

• Customer Relations (Rating 1 to 5)

• Timeliness (Ahead of Schedule, On-Time, 1-30 days late, 31 to 60 days late, 60+ days late)

• Quality of Supplies/Services (Rating 1 to 5)

• Cost Control/Quality of Invoices (Rating 1 to 5)

• Key Personnel (Rating 1 to 5)

At the very end, I must select if the Contractor either Acceptable or Not Acceptable. If Not Acceptable, I must enter in comments why the Contractor is not acceptable. Completion of the performance report takes a few seconds at a minimum, but could take much longer if the Government wanted to provide more details.

NOTE: What is missing from this list is subcontractor reporting. We already have a subcontractor reporting system, ESRS, which provide subcontractor compliance information.

What the Contractor Sees: When the Contractor views its performance it will see an aggregate of 1) the number of ratings; 2) the average rating for each category; and 3) the percentage of acceptable to not acceptable. For each of its contracts, it will be able to see whether they were acceptable or not acceptable, and if not acceptable, the comments entered by the agency. If the Contractor knows what the agency puts down, agencies will not be honest in their evaluation to avoid contention. Therefore, the majority of the data must be completely anonymous!

What the Reviewing Agency Sees: When the reviewing agency logs in, they can type in details about their current contract competition, such as:

• Contractor Name;

• Product Service Code(s);

• Dollar Value;

• Keywords (i.e. Widgets);

• Agency (can select all);

• Date Range (all ranges or specific); and

• Exact Match (Yes or No)

When they hit the search button, it will provide an overall summary, for example:

SneakyCorp 10 ratings (90-percent acceptable)

Timeliness *

Quality of Supplies/Services **

Cost Control/Quality of Invoices **

Key Personnel ***

Average **

Then, it will list the contracts that reasonably fall within the range of the search parameters. For example (I am evaluating a contract for remediation services, valued at $20 million, for all agencies within the last three years):

Contract # Description Value Score Rating

ABC-14-0001 Bio Remediation $25m ** Not Acceptable

YXZ-13-0022 Sock Remediation $15m * Acceptable

ZXY-14-0043 Bio Remediation $30m *** Acceptable

DEF-12-0064 Cat Remediation $23m * Acceptable

I can click on any of these contracts and its takes me to the breakdown of the ratings on that contract. I can see all of the pertinent information from FPDS; the ratings for each of review areas, the comments entered by the agency, the agency point of contact, etc. I can now either call the agency for more details or use this information as part of my source selection decision. At least now, the past performance information is tailored to my acquisition, easy to access, and explained in a measurable manner.

Where this system struggles is that it makes the assumption that all contractor performance is with the Federal Government. It could not handle commercial contracts because of the potential for fraud. Yet, CPARS handles only Government contracts.

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Imagine for a second a past performance system from the future.

Well, metteec, the good news is that you seem to have reduced the problem to a matter of software development.

For me, this thread has raised two main issues concerning past performance. The first is how the government evaluates it during source selection. The second is how the government reports it during and after contract performance. The two issues are related, but not the same.

The first thing to do is think about what past performance is, and I mean what it is, not how the FAR councils define it, which is as follows in FAR 2.101:

“Past performance” means an offeror’s or contractor’s performance on active and physically completed contracts (see 4.804-4).

That definition does not really answer my question: Is past performance (a) what the contractor did, ( b ) how the customer feels about what the contractor did, ( c) what the customer thinks about what the contractor did, or (d) all three? (I make a distinction between feeling and thinking. You might be angry as hell with a contractor even though your reasoning tells you that the contractor was right.)

In supply contracting, (a) is often relatively easy to know, and some might consider ( b ) and ( c) to be irrelevant.

Suppose that you have a contract for the delivery of a product to a military team in Afghanistan. The Government wants delivery of the required item on time and to the right place. The contractor does it, going the extra mile to overcome serious obstacles imposed by nature, by the enemy, and by the customer’s own incompetence. But the contractor was very nasty for the CO to deal with -- argumentative, hostile, occasionally uncooperative, sometimes insulting, always aggressively demanding, and it filed REAs and claims at the drop of a hat. The activity that received the item was aware of the serious difficulties the contractor had to overcome in order to get the item to them on time and praised the contractor to high heaven in a letter to the CO, copy to the contractor.

The CO never wants to deal with the contractor again. The requiring activity didn’t have to deal with the contractor during performance and when told about the CO’s problems could not have cared less and even sided with the contractor. It certainly matters whether the contractor was easy or difficult to deal with, but it’s hard to argue with on time delivery of a conforming item to the right place in the face of hellacious circumstances.

How should the agency rate the contractor’s performance? How should a source selection evaluation team evaluate it based on inputs from the requiring activity, the CO, and the contractor?

In service contracting, facts about performance are often hard if not impossible to know. Besides, feelings and thinking might be much more important than the facts.

Suppose that you have a service contract in which the customer is supposed to provide information to the public on demand. The S.O.W. says that the information provided must be “accurate” but does not define that term; my dictionary says: "correct in all details; exact."

Now, check out this thread:

http://www.wifcon.com/discussion/index.php?/topic/2616-difference-between-small-business-set-aside-and-total-small-business-set-aside/

Suppose further that Post #2 in that thread was the contractor’s response to the questions, which had been asked by a member of the public. Suppose still further that the person who asked the question was surprised and thrilled to receive such prompt, courteous, brief, and definite answers from the Government. However, the answers were not satisfactory by the standards of knowledgeable people, as indicated by the next two posters. If you asked the person who asked the question if he or she were happy with the answers given in Post #2, they might say yes. The person even posted, “Thank you!” But was that for the first answer, the second, or both? Was it an expression of satisfaction with the answer, or just politeness?

Clearly, the person who received the answers was in no way qualified to assess their accuracy and professional exactitude. In order to make such a judgment they would have had to know the right answers, and if they had known that they would not have asked the questions in the first place. Then again, the answers might have been just fine based on the person’s reason for asking, which we do not know. It may have met that person’s need to a “T”. But should the CO be satisfied because the customer was satisfied, even if the CO knew that the answers were not complete? How should the CO rate the contractor’s performance in this instance and in others like it?

How would source selection evaluation teams access information about such performances? How would they know whom to contact and with whom to speak? How would they contact them two or three years after performance? If they could contact them, how could they obtain and sort out the facts and sort out the feelings and thinking, or should they? How could they reconcile conflicting reports from contractor, the various government personnel, and the member of the public? In the information services contract scenario, if both the CO and the person who asked the question were satisfied with the answer, but the evaluation team were not, should the team substitute its opinion about the contractor’s performance for the opinions of those who had received the contractor’s performance?

But does an evaluation team need such detailed information or just conclusions? Is "They were great!" enough for source selection purposes? Is what someone feels or thinks ultimately more important than facts? Is it past performance as facts that we're evaluating, or is it reputation?

I’m not interested in these things from the standpoint of prospective litigation, and I don’t care about GAO, board, or Court of Federal Claims case law. I am interested in the problem of setting policy and procedure. What should contracting professionals think about how to handle these things? How do we ensure that all are treated fairly? What would be fair? What’s the best thing to do for the taxpayer? How do we ensure that the myriad government personnel involved keep good records, identify pertinent facts for reporting, and report completely and accurately? How do we ensure that sound conclusions are reached about contractor performance (a) by those who receive the performance and ( b ) those who must rate it during source selection?

Those are the kinds of questions that worry industry, task policy makers, and should interest a professional contracting workforce. Those are the kinds of things that I think a professional contracting workforce should think about, argue about, and write about. The thoughtful writers among us are few and far between and are getting older. Who will replace them?

What we have done is left such thinking, arguing, and writing to attorneys, who value such thinking, arguing, and writing, but who bring with them a particular take on problems. Thus, you can find good arguments about these kinds of things in law reviews, journals, and periodicals. (You won’t often find them in the very few contracting publications that exist.)

The legal (and I.T.) point of view dominates policy making, which, if you think about it, explains a lot about CPARS.

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I am not a contracting officer, and my contracting experience has been primarily with installation type contracting in Germany, where the majority of contracts were de facto sealed bidding and past performance was never in issue, and in legacy aircraft that did not involve source selection. I have been involved in one matter that involved a CPARS rating where I did not think the negative rating was justified by the facts recited in the rating. Take this into account when considering my comments.

1. Any rating system needs to provide other contracting officers the information necessary to evaluate the performance of the offeror under the rated contract. Is a simple rating, supported by as little or as much detail as the rater wants to provide, sufficient? As a contracting officer, how satisfied with a report would you be if all the factors were rated acceptable with no further detail? How much credence would you give to a rating of excellent if there were no details describing how the rating was earned and justified? Never having written a CPARS report, and never having used one in a source selection, I would not be satisfied in making my source selection decision/recommendaton based on simple ratings with no description of the factual basis for the rating.

2. In my opinion, the emphasis on anonymity is misplaced for two reasons. First, the regulations implementing the rating system will define who is responsible for preparing and submitting the report. The contracing officer/program manager/whoever else prepares the report will not be shielded from "contention" if the report is unsigned; that person will probably be known, and in any event will have to deal with the contractor's displeasure when the contractor learns of the rating. Second, the assumption that raters will be unwilling to provide accurate ratings without anonymity assumes raters without the intestinal fortitude to stand by their decisions. The solution is not to change the rating system so the raters remain anonymous, the solution is to rid the system of such raters.

3. It has been suggested that the comments supporting the rating should not be provided to the contractor.

What the Contractor Sees: When the Contractor views its performance it will see an aggregate of 1) the number of ratings; 2) the average rating for each category; and 3) the percentage of acceptable to not acceptable. For each of its contracts, it will be able to see whether they were acceptable or not acceptable, and if not acceptable, the comments entered by the agency. If the Contractor knows what the agency puts down, agencies will not be honest in their evaluation to avoid contention. Therefore, the majority of the data must be completely anonymous!

NOTE: The second and third sentences seem contradictory. The second sentence says the contractor will be able to see the government comments if a rating is not acceptable, while the third sentence says that allowing the contractor to see the comments will result in agencies unwilling to be honest in their evaluations. From this it is concluded that the majority of the data must be anonymous, and I assume anonymous refers to the nature of the data and not just to the author.

Again in my opinion, refusal to provide offerors with the facts and rationale supporting the rating is improper because it deprives the offeror of due process. Without access to the comments, the offeror is unable to respond in any meaningful manner.

4. Finally, I understand the problems with the length of time it takes to prepare the reports. If the reports require more information than is necessary, the report requirements should be changed. If the required information can be provided in a different, less time consuming format, by all means change the format. But do not dumb down the system, and eliminate necessary information, simply because those providing the ratings are unwilling to devote the time necessary.

CONCLUDING QUESTION: Is CPARS not working because it is inherently broken, or is CPARS not working because it is not being implemented properly? The answer to this question may determine how CPARS is fixed.

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CONCLUDING QUESTION: Is CPARS not working because it is inherently broken, or is CPARS not working because it is not being implemented properly? The answer to this question may determine how CPARS is fixed.

If in the first question "inherently broken" means poorly designed, then I take the answer for granted to be: Yes, it is inherently broken.

If in the second question "implemented properly" means in accordance with instructions, then I take the answer for granted to be: Yes, it is not being implemented properly. (What is?)

Thus, I think CPARS is a poorly designed system that is not being implemented in accordance with instructions, as is any input oriented system that requires busy people to do something that won't benefit them directly. I doubt that CPARS will be fixed by today's government, which has more important things to fix.

Did you all know that DOD had a past performance reporting system in the early 1960s? It was described in DOD Directive 5126.38, Program of Contractor Performance Evaluation, April 1, 1963. It was implemented in Armed Services Procurement Regulation § 1.908 (32 CFR § 1.908). The system was abandoned in 1971, with the explanation that "the benefits derived from CPR [Contractor Performance Report] were not sufficient to warrant the cost involved." ASPR Revision 10, Nov, 39, 1971. So if formerfed is right that CPARS is not working -- and I do not know that to be true -- then history has caught up with us.

I discussed the DOD system briefly at the beginning of a monograph published by The George Washington University Law School, How to Evaluate Past Performance: A Best-Value Approach, The Monograph Series, 2d., No. 1 (Summer 1994).

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Is it possible configurethe database to delete all information older than three years? I know we are supposed to consider the currency of past performance information, and this would be in concert with that. But more importantly it should reduce the stakes of a negative past performance rating for the offeror- hopefully reducing the number of challenges. Google never forgets, but CPARS vertainly could.

I've sent out this trial balloon in a few different places, but no one has really shot at it, so it's hard to tell if this is a good idea. I bet a platinum WIFCON member has some ammunition handy.

(A second thought: Sometimes when you and your Contractor sue each other, you settle and agree to not say nasty things about one another. Don't think this accounts for much of the data problems, but it is bound to come up occasionally.)

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apso

First remember that PPIRS is the archiving system for past performance reports generated from CPARS and ACASS (understand they are currently merging the systems). Then using a simple Google search I found the following documents that suggest strongly that CPARS retains info on contracts for three years so folks can “auto register” a contract and PPIRS retains the past performance information for three years except for construction where it is retained for six.

http://www.acq.osd.mil/dpap/ccap/cc/jcchb/Files/Topical/Past_Performance/guides/cpars_user_manual_2010_dod.pdf

(While this guide is dated it is referenced on the PPIRS website as being the most current reference.)

http://www.acq.osd.mil/dpap/Docs/PPI_Guide_2003_final.pdf

Additionally found this interesting GAO Decision that in part is related to this thread as it discusses both PPIRS and commercially available information on past performance.

http://www.gao.gov/assets/670/661016.pdf

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