CPARSContractor Performance Assessment

Reporting System

210 Procurement All-hands – May 28, 2014

Upcoming Dates

• No new evaluations may be initiated between 5/28/2014 at 1159 ET and 7/1/2014.

• In-process evaluations that are not completed by 6/27/2014 at 1159 ET will have a loss of data and will be returned to Drafted status if they are at Rated, Reviewed or Finalized status.

• CPARS/ACASS/CCASS/FAPIIS will be unavailable 6/28/2014 - 6/30/2014.

• The new merged CPARS system will be available on 7/1/2014.

CPARS vs. PPIRS

• Contractor Performance Assessment Reporting System (CPARS)– Online applications to input performance information.

• Past Performance Information Retrieval System (PPIRS)– Online application to view performance information.

• Weekly feed from all four CPARS applications. • Used for source selection purposes. • Retained in PPIRS for three years after contract ends.

Performance Assessment Process

CPARS PPIRS

Assessing Official - Contracting Officers

Contractor Representatives

Gov’t Source Selection Officials

Contractor Senior Management

Why Evaluate Contractor Performance?

• FAR 42.1502– Past performance evaluations are required for contracts and

orders for supplies, services, research and development, and contingency operations, including contracts and orders performed inside and outside the United States

• FAR 15.304– Past performance shall be evaluated in all source selections for

competitive negotiated acquisitions expected to exceed the simplified acquisition threshold ($150K)

• FAR 9.105– FAPIIS/PPIRS shall be used to support responsibility

determinations

CPARS – What Does it Look Like Today?

• CPARS– Web-enabled application that collects and manages a library of

automated contractor report cards• CPARS currently contains four individual systems:

– CPARS is the input system for contractor performance assessment reports (CPARs)

– CCASS is the input system for performance evaluations on construction contracts

– ACASS is the input system for performance evaluations on architect-engineer contracts

– FAPIIS is the input system for terminations for cause, defective pricing, non-responsibility determinations and administrative agreements

CPARS – What Will it Look Like Tomorrow?

• The CPARS, ACASS, and CCASS modules are being merged into a single application under the CPARS name in order to standardize the contractor performance evaluation process across the entire Federal Government.

• Historically, CPARS, ACASS, and CCASS have contained differing contractor evaluation forms, rating elements, and workflow processes. The merge includes the transition to a common evaluation form with a common set of rating elements in addition to a transition to a common workflow process. These changes are designed to promote system usability by simplifying the evaluation process.

CPAR – What is it?

• A Contractor Performance Assessment Report (CPAR) assesses a contractor's performance and provides a record, both positive and negative, on a given contractor during a specific period of time. – Each assessment is based on objective facts and supported

by program and contract management data, such as cost performance reports, customer comments, quality reviews, technical interchange meetings, financial solvency assessments, construction/production management reviews, contractor operations reviews, functional performance evaluations, and earned contract incentives.

CPAR – When to Report

• Thresholds: – A CPAR is required if the total potential value of the contract

exceeds the simplified acquisition threshold ($150K). – IDIQ orders are considered together for thresholds, but may

be evaluated separately. – FSS orders and BOA orders are considered and evaluated

individually. – The Government can report on contracts below the

threshold in special circumstances (e.g., to help a small business, to document exceptionally good/bad performance, etc.).

CPAR – Types of Reports• Four types of CPARs: Initial, Interim, Final, Out of Cycle

– Initial/Interim (Intermediate) Reports • Required if period of performance is greater than 365 calendar days (the initial report may be

the first interim report and reflect at least the first 180 calendar days of performance) • Not required if period of performance is less than 365 calendar days – see final report below

(write the final report). • Interim evaluations are not required on contracts whose award anniversary is within 3 months

of the end of the contract period of performance. The final evaluation will include an evaluation of the period between the last interim evaluation and the end of the contract period of performance.

• Evaluation period commences at contract award.• An interim report is required every 12 months based on contract award date. Not cumulative. • Assessment is done for the performance occurring since last evaluation period. • Complete with other reviews (e.g., Performance Evaluation and Measurement Reports, Contract

Management Plans, Option Exercise, Award Fee Determinations, and Program Milestones). • Required upon a significant change in contractor performance. • Recommended prior to transfer of Assessing Official duties to another individual to ensure

continuity.• Interim evaluations are optional for SBIR/STTR Phase II contracts. • Completion of the report is due 120 calendar days after the end of the assessment period.

CPAR – Types of Reports– Final Report

• Required if there is a contract termination. • Required at Contract completion (end of period of performance); or Delivery of

final end item(s). • A final report is due within 120 calendar days after the end of the evaluation

period. • Not cumulative. • The report assesses only performance occurring since last evaluation period.

– Out-of-Cycle Report

• Written, if there is significant change in performance that alters the evaluation in one or more evaluation areas, at Government’s discretion; or Contractor’s request.

• Address only those areas that have changed. • No more than 1 out-of-cycle report may be completed per 12 month period of

performance. • Out-of-cycle evaluation does not alter the annual reporting requirement

CPAR – Key Roles

• Assessing Official (AO) – Program Manager, Contracting Officer, Contracting Officer’s Representative, IPT lead, etc. – Writes evaluation, reviews contractor comments. – Must be a Government employee.

• Contractor Representative – Someone involved in day-to- day performance – Reviews evaluation, writes contractor comments.

• Reviewing Official (RO) – One level above the Contracting Officer – Reviews contractor comments, returns to AO for correction if

necessary, inputs supplemental comments. – Must be a Government employee.

CPAR – Evaluation Process• Step 1 – Contract Registration. Allows general contract information to be entered by anyone assigned

those responsibilities. Contracts must be registered within 30 days after contract award. • Step 2 – Enter Proposed Ratings. Allows individuals assigned to management of specific contracts as an

Assessing Official Rep/Assessing Official to enter proposed ratings and supporting narrative or remarks. These ratings are relative to the contractor’s performance for a specific contract.

• Step 3 – Validate Proposed Ratings. Allows the Assessing Official to establish performance ratings and/or modify proposed ratings for specific contracts. The Assessing Official is required to enter their name, title, organization, etc., and forward the assessment to the Contractor Rep for review.

• Step 4 – Contractor Comments. Allows the Contractor Rep being evaluated to review the proposed ratings and comment on any elements that may require further review or explanation. After review the Contractor Rep returns the assessment to the Assessing Official to continue with the workflow process.

• Step 5 – Review Contractor Comments. Allows the Assessing Official to accept and finalize the assessment, or modify the proposed ratings and narrative, and/or forward the assessment to the Reviewing Official. If ratings are modified, the original proposed ratings are archived and then both ratings are forwarded to the Reviewing Official for review, comment and closure.

• Step 6 – Reviewing Official Comments. Allows the Reviewing Official (if applicable) to review the ratings established by the Assessing Official and the response by the Contractor Rep to ensure that the ratings are fair and supported by objective evidence. The Reviewing Official is required to comment and close the assessment.

• Once the Reviewing Official completes the actions of step 6, the assessment is considered complete. Completed assessments are copied weekly to the Federal Past Performance Information Retrieval System (PPIRS) database.

CPAR – What is Evaluated?

• Evaluation factors for each assessment shall include, at a minimum, the following:– Technical (quality of product or service).– Cost control (not applicable for firm-fixed-price or fixed-price with

economic price adjustment arrangements).– Schedule/timeliness.– Management or business relations.– Management of key personnel (if applicable).– Small business subcontracting.– Other (as applicable) (e.g., late or nonpayment to subcontractors,

trafficking violations, tax delinquency, failure to report in accordance with contract terms and conditions, defective cost or pricing data, terminations, suspension and debarments).

CPAR- What is Evaluated?

• For Cost Plus Award Fee or Fixed Price Award Fee type contracts– Contracting Officers shall complete the following evaluation

information in the Award Fee Evaluation System module in the NASA Acquisition Internet Service: • available award fee amount, • amount of award fee earned, • award fee rating, • how the use of award fee did or did not motivate the contractor’s overall

cost, schedule and technical performance as measured against contract requirements in accordance with the criteria stated in the award fee plan and how the objectives were enhanced by using an award fee contract as stated in the determination and findings required at FAR 16.401(d).

CPAR – Evaluations• Each factor and subfactor used shall be evaluated and a supporting

narrative provided. • The evaluation should include a clear, non-technical description of the

principal purpose of the contract or order. • The evaluation should reflect how the contractor performed. • The evaluation should include clear relevant information that accurately

depicts the contractor’s performance, and be based on objective facts supported by program and contract or order performance data.

• The evaluation should be tailored to the contract type, size content, and complexity of the contractual requirements.

• Each evaluation factor, shall be rated in accordance with a five scale rating system (i.e., exceptional, very good, satisfactory, marginal, and unsatisfactory).

CPAR – Narrative Rating Definitions

Rating Contract Requirements Problems Corrective

Actions

ExceptionalExceeds Many – Gov’t Benefit

Few Minor Highly Effective

Very Good Exceeds Some – Gov’t Benefit Some Minor Effective

Satisfactory Meets All Some Minor Satisfactory

MarginalDoes Not Meet

Some-Gov’t Impact

Serious: Recovery Still

Possible

Marginally Effective; Not Fully

Implemented

UnsatisfactoryDoes Not Meet

Most-Gov’t Impact

Serious: Recovery Not

LikelyIneffective

CPAR – Small Business Utilization Rating Definitions

Rating Subcontracting Plan ISR/SSR Benefits/Impacts

ExceptionalMet All Goals &

Exceeded at Least One

Accurate & Timely

Multiple Significant Events of Benefit

Very Good

Met All Traditional

Goals & at Least One Other Goal

Accurate & Timely

Significant Event of Benefit

Satisfactory Good Faith Effort to Meet Goals

Accurate & Timely

Minor Problems; Major Problems

w/Corrective Action

Marginal Deficient in Meeting Key Plan Elements

Inaccurate; Untimely

Corrective Action Plan Required

Unsatisfactory Noncompliant; Uncooperative

Inaccurate; Untimely

Multiple Significant Problems;

Liquidated Damages

CPAR – Contractor Feedback• Contracting Officers shall ensure that the Government discusses all evaluations with

contractors and shall record the date and the participants on the evaluation form. – The contractor will receive a CPARS-system generated notification when an evaluation is

ready for comment. Contractors shall be given a minimum of 30 days to submit comments, rebutting statements, or additional information.

– Contracting officers shall sign and date the evaluation after considering any comments received from the contractor within 30 days of the contractor's receipt of the evaluation.

• If a contractor in its timely comments disagrees with an evaluation and requests a review at a level above the contracting officer, it shall be provided within 30 days.

• Copies of the evaluation, contractor response, and review comments, if any, shall be retained as part of the evaluation. These evaluations may be used to support future award decisions, and should therefore be marked “Source Selection Information”.– While the FAR requires agencies to use contractor performance information that is within

three years (six years for construction and architect-engineer contracts) of the completion of contract performance, this information shall nevertheless be retained in the contract file as provided in FAR 4.8, Government Contract Files.

CPAR – Sensitive Information

• All CPARS information is treated as “For Official Use Only/Source Selection Information” in accordance with FAR 2.101 and 3.104 and 42.1503. – A CPAR is source selection information because it supports

ongoing source selections. It contains sensitive data concerning a contractor’s performance under a specific business arrangement as covered by the FAR.

– A CPAR has the unique characteristic of always being pre-decisional in nature. Distribution of CPARs will be made solely through use of PPIRS at http://www.ppirs.gov/.

– Access to the CPARS AIS and other performance information is restricted to those individuals with an official need to know.

CPAR – Narrative Guidelines• Address Contractor Performance

– Recent – Relevant

• Collect Input From Entire Program / Project Team• Provide Reader a Complete Understanding of the Contractor’s

Performance• Address

– Rating Changes From Prior Reports– Benefit / Impact to Government

• Recognize– Risk Inherent in Effort– Government’s Role in Contractor’s Inability to Meet Requirements

• Indicate Major / Minor Strengths / Weaknesses

CPAR – Narrative Guidelines

• Consistent with – Program Metrics– Ratings– Contract Objectives

• Document Problems & Solutions• Contain Non-Personal & Objective Statements

Program Reviews& Status Reports

Earned Value Management (EVM) Data

Award Fees/Incentives

Certificates of Service

Cost Performance Reports

Inspection Reports

Schedule

CPAR – Narrative Statements to Avoid

Outside Contract Scope

In Our Opinion

It Appeared

We Believe

We Hope

We Were Not Happy

We Did Not Like

We Think

CPAR – Helpful HintsPrior to Period of Performance

• Be Up Front– Identify Expectations– Discuss Areas to be Evaluated

• Provide Policy Guides to Contractors and Evaluators– During Post-Award Conference– Prior to Annual Evaluation

• Leave Yourself Flexibility– Don’t wait until the annual evaluation to make your contractor aware

of performance!

CPAR – Helpful HintsDuring Performance Period

• Communicate with Contractor– Provide Feedback

• Document Performance Regularly – Status Reports – Earned Value Management Data– Monthly Certificates of Service– Award Fee Evaluations– Program Reviews– Earned Contract Incentives

CPAR – Helpful HintsAfter Performance Period

• Provide Contractor Draft Assessment

• Contractor May Provide Self Assessment

• Take Time to Acknowledge Contractor Concerns– Face to Face Meetings– Extend 30 Day Comment Period if Necessary

• Document File if no Contractor Comments Received– Transmittal Letter Email– Phone Conversation– Efforts to Contact Contractor

Back-Up Charts

Quality of Product or Service

• Assess Conformance to:– Contract Requirements– Specifications– Standards of Good Workmanship

• Are reports/data accurate?

• Does the product or service meet the specifications of the contract?

• What degree of Government technical direction was required to solve problems that arose during performance?

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Schedule

• Assess Timeliness of Completion Against:– Contract– Task Orders– Milestones– Delivery Schedules– Administrative Requirements

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Cost Control

• Assess Effectiveness in Forecasting, Managing, Controlling Contract Cost

• Does the Contractor keep within the total estimated cost?– Negotiated/Budgeted Costs vs Actuals

• Did the Contractor do anything innovative that resulted in cost savings?

• Were billings current, accurate, and complete?

• Are the Contractor’s budgetary internal controls adequate?

Business Relations

• Assess Integration and Coordination of All Activity Needed to Execute Contract– Problem Identification– Corrective Action Plans– Reasonable & Cooperative Behavior– Customer Satisfaction– Timely Award & Management of Subcontracts

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Business Relations

• Assess Integration and Coordination of All Activity Needed to Execute Contract– Problem Identification– Corrective Action Plans– Reasonable & Cooperative Behavior– Customer Satisfaction– Timely Award & Management of Subcontracts

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