John Andre (JA): Hello, thank you for joining today's Acquisition Seminar hosted by the Federal Acquisition Institute. Today’s seminar entitled Key Elements of Past Performance, Information, and Best Practices for Reporting Timely and Quality Evaluations features great presenters from the Office of Management and Budget, departments of the Navy, Defense, Treasury, and Homeland Security, the National Aeronautics and Space Administration, and Environmental Protection Agency.
The federal acquisition workforce is pressed to be efficient and fiscally responsible when planning, sourcing, selecting, and awarding contracts and orders to contractors. Great efforts have been made to improve past performance guidance and establish new tools to help agencies improve their reporting. Leveraging these tools and sharing agency best practices for the timely reporting of quality past performance information will only increase agencies’ ability to deliver better outcomes and increase productivity on behalf of the American taxpayer.
This seminar will provide an overview of key elements of past performance information as well as the tools and systems that are available for past performance reporting and reviewing. We will learn how agencies ensure that: one, their acquisition workforce understands their role in the past performance process, two, their workforce reports past performance information in a timely manner, and three, all performance issues, mitigation steps, and resolutions are accurately documented in the performance systems and made transparent to the contractor during the period of performance. We will learn this from:
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Julia Wise, Acquisition Regulatory Manager and Senior Procurement Analyst Office of Federal Procurement Policy, Office of Management and Budget
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Doreen Powell, Quality Assurance Specialist, Contractor Performance Assessment Reporting System Program Management Office, Naval Sea Logistics Center, the Department of the Navy
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Richard Ginman, Director, Defense Procurement and Acquisition Policy, Department of Defense
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William McNally, Assistant Administrator, National Aeronautics and Space Administration
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Iris Cooper, Senior Procurement Executive, Department of the Treasury
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John Bashista, Director, The Office of Administration and Resources Management, Environmental Protection Agency and
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Laura Auletta, Executive Director of Procurement Policy and Oversight, Department of Homeland Security.
Before we begin, allow me to explain a few administrative items. First, the Federal Acquisition Institute is recording this seminar. The video, as well as the material you see today, will be posted in the video library on fai.gov. You should be able to access these items in one to two weeks. Second, we usually ask you to submit question using the link on this page so we can hold a live question and answer session with our presenters at the end of the seminar. However, our agenda is too full for that today. Instead we would ask that you submit questions or concerns related to past performance you wish to see addressed in future training offerings.
Now let's get started. It is my distinct honor to introduce Lesley Field. Ms. Field is the Deputy Administrator for Federal Procurement Policy in the Office of Management and Budget, Executive Office of the President and is currently serving as the acting administrator, a position she has held periodically since 2008. Prior to joining the Office of Management and Budget, Ms. Field served at the U.S. Department of Transportation as a contracting officer in the Office of the Secretary. Ms. Field is also a fellow of the National Academy of Public Administration and a 2008 winner of the Fed-100 Award. Let's go to her now.
Lesley Field (LF): Hello, I am Lesley Field, the Acting Administrator for Federal Procurement Policy in the Office of Management and Budget and I'm pleased to welcome you to today's Acquisition Seminar on past performance. Over the past five years, OFPP has placed great emphasis on reporting compliance and the use of past performance information to ensure taxpayer dollars are being spent wisely.
Most recently, in 2013, we set aggressive targets to improve timely reporting and I’m pleased to report that every one of the CFO-Act agencies has improved. We have also worked with the Federal Acquisition Regulatory Council to develop a central reporting tool and standardized evaluation factors and rating criteria to require that all agency procedures include clear roles and responsibilities and to make performance information immediately available to other source selection officials. We will continue to make regulatory and policy and systems changes to improve the collection and use of this information and today's session is designed to reinforce the value of getting and sharing performance assessments.
Before the seminar begins I’d like to quickly explain why we are focusing on not only improving reporting compliance but also on how to use this information in your source selection decisions. Past performance is one of the most relevant factors that a selection official should consider in awarding a contract. The evaluation of contractor performance and the use of those evaluations and decisions for future awards motivate contractors to perform well and helps ensure we do not repeat business with firms that do not perform, and it is especially important in high risk, complex acquisitions.
We also want to be sure we are able to tap the innovation that new entrants, those with little or no Federal experience, can bring to the table. Many agencies have established policies that require their acquisition workforce to consider relevant information from other agencies, commercial customers, state and local governments, and even foreign governments, if doing so would provide constructive information about performance risks or issues that may be associated with a particular business. Selection officials are encouraged to conduct more outreach for example, calling a colleague, do more research off-line, and using other sources of information, especially for new entrants so that we get a new picture.
Agencies are doing more than ever to improve reporting so that the performance system includes useful and quality information. You will hear strategies and practices today from some of our key senior leaders, so I encourage you to take notes and share with us your practices that may or may not have been mentioned today. Once collected, we will share your improvement strategies across the government with other acquisition practitioners. Thank you.
Julia Wise (JW): Hello, my name is Julia Wise. I am with the Office of Federal Procurement Policy. As Ms. Field mentioned, today’s session will provide valuable information about past performance. You will also hear senior acquisition leaders discuss their agency best practices. These are practices they have implemented within their agencies to improve the timely reporting of quality performance information into the systems. For many acquisition professionals, this information will refresh your knowledge of this topic and for some, this information will be new, but for everyone, we hope this session emphasizes the importance of using past performance information effectively during the source selection process and when managing contractor performance. And also when documenting quality performance information into the system.
Today’s session will cover background information, policies and regulations, and discuss named elements of past performance information. You will hear about the what, why, when, and who is responsible for reporting timely and quality information. You will also hear about the past performance information systems: where information is reported and how quality information is recorded into the systems. There will be five key agencies such as Department of Defense, including Navy, Department of Homeland Security, Environmental Protection Agency, NASA, Department of Treasury will be here to discuss their best practices for reporting timely and quality information into the system. Primarily they will focus on the areas of accountability, compliance, and transparency.
First, let's start with the long history associated with past performance. The OFPP Act of 1974 required the OFPP administrator to prescribe guidance regarding the consideration of past performance of offers in awarding contracts. Specifically, it required the policies and procedures to establish standards for evaluating past performance with respect to cost when appropriate, schedule, compliance with technical or functional specifications, and other relevant performance factors that facilitate consistent and fair evaluation by all executive agencies. It also required policies for the collection and maintenance of information on past contract performance that to a maximum extent practical facilitate automated collection, maintenance, and dissemination of information, and provides for ease of collection, maintenance, and dissemination of information by other methods as necessary. It also required policies for ensuring offers are afforded an opportunity to submit relevant information on past contract performance including performance under contracts entered into by the executive agencies concerned by other agencies, state, and local governments, and by commercial customers, and that such information is considered. The policies were also required to include the period over which past performance information may be maintained.
Then we also have the Federal Acquisition Streamlining Act of 1994 which is known as FASA. FASA was designed to eliminate red tape and to permit the government to behave more like the private sector. It modeled the private sector practice of awarding to companies with strong performance records. FASA also stated that it was appropriate and relevant that a contracting official consider a contractor's past performance as an indicator of the offeror's ability to perform the contract successfully. It also stated that an offeror that has no information on past contract performance or no past contract performance information available may not be in Valley weighted favorably or unfavorably on the factor of past contract performance. FASA required the administrator of OFPP to establish policies and procedures that encouraged the consideration of offerors’ past performance in the selection of contractors.
OFPP issued a policy letter which is known as 92-5 that established requirements for evaluating contractor performance and for using past performance information in the source selection process. The OFPP Act and FASA requirements and the OFPP policies are all contained in the Federal Acquisition Regulation (FAR) parts 9, 12, 13, 15, 36, and 42.
Over the past five years, OFPP has issued additional policy guidance to strengthen the agency use of past performance information and to improve agency reporting compliance and documentation. OFPP's July 29, 2009 memorandum entitled Improving the Use of Contractor Performance Information described new FAR requirements to strengthen the use of contractor performance information. It also included agency management responsibilities and established OFPP's review process for evaluating agencies effective reporting of contractor performance information. In January 2011, OFPP also issued another memorandum entitled improving contractor past performance assessments. It included a summary and strategies for improvement of past performance information. It also included OFPP's initial assessment of agencies’ reporting of contractor performance information and additional strategies for improving the collection of past performance information. We recently issued a memorandum in 2013 entitled Improving the Collection and Use of Information about Contractor Performance and Integrity Information, which requested agencies to 1) establish a baseline for reporting compliance, 2) set aggressive performance targets that OFPP and agencies can use to monitor and measure reporting compliance, and three, it also required agencies to ensure the workforce is trained to properly report and use this information to improve the collection and use of performance and integrity information. Additional guidance is planned to enhance agencies’ use of performance information, making certain that we conduct research and outreach without public and private sector acquisition colleagues to obtain as much relevant and recent performance information about a contractor's performance history.
With regards to regulatory changes in the area of performance, we have issued numerous changes over the past five years, starting with mandating the use of standard performance information reporting systems known as the Past Performance Information Retrieval System (PPIRS). We also established procedures to ensure that contracting officers provide contractor information such as terminations for cause or default and effective cost or pricing data into the past performance information system and into the federal awardee performance and integrity system module within PPIRS. We standardized the past performance evaluation factors in rating criteria used in the contracting evaluation and CPARS. Future changes will include requiring that contractors are provided up to 14 calendar days from the date of delivery of past performance evaluations and to CPARS to submit comments, rebuttals, or additional information pertaining to past performance for the inclusion in the database. FAR subpart 42-15 will also be updated to accommodate the consolidation of the A&E contract information support systems and the construction contractor appraisal support system into the one CPARS database. In the area of integrity, several regulatory changes were made to establish the Federal Awardee Performance and Integrity Information System known as FAPIIS and that system includes government and contractor reported integrity information. This information is also publicly available on the website.
As you can see on the screen, we have a list of the different regulatory changes that have been made. If you want to follow how these cases are progressing, you can go to our website, the OFPP website, for information on the different regulations.
So what is past performance information? Past performance information is relevant information for source selection officials regarding a contractor's actions under previously awarded contracts and orders. It includes the performance ratings and narratives that support the rating assigned. The past performance evaluation report includes information about the contractors, record of conforming to requirements and to standards in the contract. It includes records of estimated and controlling cost. It also includes their adherence to contract schedules, including administrative aspects of performance. We also want to include in this report, history of reasonable and cooperative behavior and commitment to customer satisfaction. A record of their integrity and business ethics is also included, as well as business-like concern for the interest of the customer. This information is a likely indicator of future performance. For certain requirements, the use of past performance as an evaluation of factors can be highly effective in reducing the government’s risk.
So why is past performance information used? Past performance information is used to aid the government's decision process and to ensure we award contracts to companies that consistently produce and deliver quality products on time and within schedule. FAR parts 9, 15, and 42 all discuss why past performance information is used, during the pre-award process. For example, in the contract [inaudible] section, FAR sub-part 9.104-1, it says it is used as one factor in determining contractor responsibility. In FAR 15.304, Contracting by Negotiation, it is used to validate statements made in the company's proposal. We look at the capability, experience, and risk and it is an integral part to ensure that we get the best value doing the source selection process. And it addresses past performance as an evaluation factor.
Agencies also use PPIRS data that is within three years (six for construction and A&E contracts) of the completion of the performance of the evaluated contract or order and information contained in Federal Awardee Performance and Integration System known as FAPIIS. We look for them to report in their terminations for default or cause. It is also used during the post-award contract administration process. In this part of the FAR, 42.15, it addresses the collection of contractor performance during the period of the contract. What are some of the benefits of using past performance information?
The main purpose of past performance information is to appropriately consider each offer as demonstrated record of performance in supplying products and services that meet users’ needs, including cost and schedule. Performance information is beneficial to source selection officials during the source selection process because it represents useful information about a contractor's past performance record and tells the story of the contractor's performance, both good and bad. It is a key indicator for predicting future performance in the performance quality, technical ability, and customer satisfaction. It gives insight into the contractor's actual ability to perform the work as opposed to relying strictly on proposal promises. It can be a powerful incentive for contractors to maximize performance and customer satisfaction on their current contracts. Performance information outside of PPIRS provides a full view of a contractor's performance ability, on contracts of similar size and scope from commercial, state, local, and even foreign governments.
So what are the benefits of using past performance information in the contract administration process? Past performance information is used during this process and the benefits of it are it documents contractors’ performance annually to make sure contractors are performing the work and government deliverables are received. It promotes communication with your contractors. It motivates contractors to strive for performance, excellence, and customer satisfaction. It also recognizes good performance and reduces performance risk and supports contract oversight. Periodic performance evaluations during contract administration not only provide a way to track contractor performance, but also encourage excellence in performance. Past performance evaluation reports are equivalent to an annual performance appraisal or school report card if you have children. So when is past performance information reported? Past performance evaluations are required for contracts and orders for supplies, services, research and development, and contingency operation contracts including contracts and orders performed inside and outside the United States expected to exceed the simplified acquisition threshold which is now $150,000 with some exceptions. For each construction contract, the recording threshold is $650,000 or more. For each A&E contract, which is known as architect and engineering service contracts, the reporting threshold is $30,000 or more.
Additionally, if the contract includes a small business subcontracting plan, past performance evaluation should include an assessment of contractor performance and efforts to achieve goals identified in the small business subcontracting plan. Evaluations and past performance systems should be completed within a timely manner after the end of the contract or order evaluation period. Contracting and program officials should evaluate contractor performance during performance and when the contract is completed to ensure effective contract administration and to provide information required to support future award decisions.
So who evaluates contractor performance? The principal goal of a past performance evaluation and rating system is to collect and present accurate and relevant contractor performance information to the official making a source selection decision. That is why it is important that the evaluation is done by individuals who have knowledge of the contractor’s performance. Evaluation of a contractor's performance should be a shared responsibility within the acquisition community with members from the program office, requirements office, and contracting office all documenting their knowledge of the contractor's performance. Agency procedures can identify many individuals responsible for evaluating the contractor's performance. Evaluation input can be obtained from many sources such as the contracting officer or contract specialist, administrative contracting officer, the contracting officer representative, or the contracting officer technical representative, the program manager or the equivalent individual responsible for the program, project, task, job, or delivery order execution. Performance evaluators and quality assurance evaluators, auditors, and users of the product or service and any other technical or business advisor involved in the contract may be responsible for documenting performance. If agency procedures do not specify the individual responsible for past performance evaluation duties, the contracting officer is responsible for this function.
Now I will talk a little bit about how a contractor performance is evaluated. Contractor performance will be assessed and rated on the following technical evaluation factors. It will be rated on their technical ability, the quality of the product or service provided to the government. We will also evaluate them on their cost control which is generally not applicable to firm fixed price or fixed price with economic price adjustment arrangement contracts. We will also look at the schedule in timeliness in terms of making sure they comply with the government’s time frames. We will also look at their management of business relations and rate them on how they deal with the customer agencies. We will look at their small business subcontracting plan and look at how they work with their small businesses and we will also look at other applicable areas such as if they have late or nonpayment to sub-contractors, if they have committed any trafficking violations, and we will also document and rate them on their tax delinquencies, whether or not they have tax delinquencies, and there is many more information than they can be evaluated on as long as that information is mentioned to them in their contracts and their solicitations.
Each factor and sub-factor is evaluated and rated in accordance with a five scale adjectival rating system. We usually rate them in the following categories. They would either receive an exceptional, very good, satisfactory, marginal, and unsatisfactory, and a supportive narrative will be provided the documents and supports the rating assigned.
So where is past performance information reported? Agencies report past performance information into the Contractor Performance Assessment Reporting System known as CPARS. CPARS is a suite of web enabled applications that are used to document and collect performance information. Assessment ratings and clear and completed narratives in supporting ratings are included in this documentation. Evaluation should include a clear non-technical description of the principal purpose of the contract or order, reflect how the contractor performed, include clear and relevant information that accurately depicts the contractor’s performance based on objective facts reported by programs and contract or order performance data. And tailored to the contract type, size, content, and complexity of the contractual requirements. Assessing officials should discuss contracting order performance with the contractor during the performance period and during the CPARS process. Assessing officials should document positive and negative performance, how problems are resolved, adjustments made to mitigate risk, and any other relevant information about the contractor's performance.
So let’s talk a little bit more about the CPARS evaluation process and the other companion system that goes along with CPARS known as PPIRS. CPARS evaluations, including any contractor submitted information are automatically transmitted to the Past Performance Information Retrieval System known as PPIRS not later than 14 days after the date on which the contractor is notified of the evaluations availability for comment. PPIRS is a central warehouse for performance assessment reports received from CPARS. Agencies are required to monitor their compliance with the past performance evaluation requirements and use the CPARS and PPIRS metrics tools to measure the quality and timely reporting of past performance information. So when we talk about access to past performance information, agencies should make sure they have appropriate management and technical controls in place to ensure that only authorized personnel have access to the CPARS and PPIRS data. Contractors can only review their own evaluation reports and agency should make sure that that access is only granted to the contractor being evaluated.
As you are aware, agencies are reporting integrity information into another system known as FAPIIS. I will give you some background information about the integrity information. Section 872 of the National Defense Authorization Act of Fiscal Year 2009 required the General Services Administration to develop and maintain a database containing specific performance and integrity information on potential awardees to support award decisions or actions over $500,000. The Federal Awardee Performance and Integrity Information System known as FAPIIS was established as a module within PPIRS. Section 3010 of the supplemental appropriations act of 2010 required that information in FAPIIS, excluding path performance reviews, be made publicly available. FAPIIS requires agencies and contractors to record negative performance integrity information. FAPIIS includes contractors’ self-reported information regarding their criminal convictions, civil liabilities, and adverse administrative actions where there was a finding of fault or damages of $5,000 or more. $100,000 for administrative agreements if the contract value is expected to exceed $500,000 and contractor or grantee has federal contracts and grants with total value greater than $10 million. The government is required to report information such as terminations for default, terminations for cause, non-responsibility determinations, defective pricing information, administrative agreements, terminations for material failure to comply, recipient not qualified determinations, and DoD is required to report determinations of contractor fault. Agency shall ensure information is accurately reported in the Federal Awardee Performance and Integrity Information System module of CPARS within three calendar days after a contracting officer makes a final decision.
The next two slides include five performance integrity information citations starting with FAR part 9.104 all the way down to FAR 52 209-9. These citations include information about how to use past performance information during the source selection process as well as during the contract administration process when you are evaluating the contractor's performance. For policy guidance, please visit the OFPP website and also see your agency’s specific guidance for more information about how to document past performance information as well as your agency's rules and procedures with regards to past performance. Please submit questions about OFPP past performance policies to me at my e-mail address listed here as well as submit your agency best practices and procedures to the OMB Max website listed on the slide.
LF: Next you will hear from Doreen Powell. Doreen is a quality assurance specialist with the Contractor Performance Assessment Reporting System (CPARS) Program Management Office at the Naval Sea Logistics Center in Portsmouth, New Hampshire. She will provide an overview of the past performance process and the best practices agencies can use to submit a quality evaluation.
Doreen Powell (DP): Hello, my name is Doreen Powell and I am from the CPARS program office at the Naval Sea Logistics Center. This session will cover The Contractor Performance Assessment Recording System or CPARS, and the Past Performance Information Retrieval System, PPIRS. During the session we will see an overview of the past performance process including the contributors to past performance evaluation, the users of that evaluation, and the relationship between CPARS and PPIRS. Next we will review the areas of contractor performance that are evaluated as taken from the Federal Acquisition Regulation, FAR, and the Federal Guidance for CPARS document. We will examine the elements that make up an evaluation with a particular focus on the most important parts of the evaluation which are the narrative comments, examples of best practices for writing a quality narrative for the evaluation will be provided during the session. We will also take a look at some upcoming improvements to CPARS and PPIRS and will conclude the session with an overview of the resources available on the CPARS and PPIRS website as well as the point of contact information for the CPARS and PPIRS helpdesk.
CPARS is the automated information system used to record contractor past performance information. Government contracting and programming officials use CPARS to prepare an evaluation or report card documenting the contractor performance on a given contract for a specific period of time. Contractor representatives also provide input to the evaluation in CPARS by entering comments to reflect whether they concur or do not concur with the government's assessment of their performance. The evaluation is transferred from CPARS to PPIRS where it is retrieved by government source selection officials, to aid in making best value award decisions during source selections. The evaluation is also available via PPIRS to senior management and the contractor who is the subject of the evaluation.
Six areas of contractor performance are rated and described on the evaluation. These areas are listed in both the FAR and the Federal Guidance for CPARS document. The first area evaluated is the quality of the product or service provided by the contractor. For this area, the evaluator compares the quality of the good or service to the requirements in the contract in terms of performance parameters or quality objectives. Quantitative measures should be used to describe contractor performance wherever possible. For example, if the contractor is operating a software support help desk and is required to resolve customer called within a one-hour timeframe, the evaluation should compare the one-hour contract requirement to the contractor's actual resolution time. Quality evaluation should also address the contractor's management of the quality control program and the overall quality of the work or service.
The secondary area of evaluation is schedule. Here in in this area, the evaluator should compare the date of delivery for the good or service to the delivery date required in the contractor order. The assessment for the area should address the timely completion of the contractor order and the timely completion of the major performance milestones. For example, the evaluation should answer questions such as: Was the overall final deliverable provided on time? What was the benefit to the government if delivery was made early, or what was the impact to the government if the deliverable was late? Were reports and data deliverables on time? In addition, the schedule evaluation area should address administrative requirements such as contract closeout documentation were provided in a timely manner.
The third evaluation area is cost control. In this area, the evaluator discusses the contractor's performance in terms of forecasting, managing, and controlling cost. Actual costs are compared with the budgeted cost for the contractor order to determine if they are consistent. Any cost overruns or under runs are addressed along with their impact or benefit to the government. For example, if there was a cost overrun, the supporting narrative may address what areas of performance had to be de-scoped in order to cover the overrun. If there was a cost under run, the narrative may address other areas within the scope to which the funds could be applied in order to generate additional benefits to the government. Cost control is not evaluated on fixed-price contracts or orders.
The fourth area of contractor performance that is evaluated is management. In the management area, the contractor's integration and coordination of all activity necessary to ensure that the contract performance meets requirements is evaluated. The contractor's ability to proactively identify performance problems and then to develop successful corrective action plans is assessed. The contractor is also rated on whether they have displayed reasonable and cooperative behavior and a businesslike concern for the customer, as well as overall customer satisfaction. When evaluating the management area it's important for the performance evaluator to consider input from the many stakeholders who are impacted by the contractor's management, including the program office, contracting officers representative, contracting officer, and product or service end-users. The contractor's ability to successfully coordinate the activities of subcontractors is also addressed in this area if applicable. In addition, the management evaluation are includes an assessment of the contractor program management efforts and the management of key personnel if the contract contains a key personnel clause.
The fifth evaluation area is utilization of small business. In this area, the contractor's compliance with the terms and conditions for small business participation in contract performance is evaluated. The contractor's achievement of their small business subcontracting goals is addressed, including their initiatives to assist, promote, and utilize small business, small disadvantaged business, women-owned small business, hub zone small business, veteran owned small business, and service disabled veteran owned small business. The supporting narrative for this evaluation area should address the percentage of the goals that were achieved by the contractor as well as their good faith efforts to provide meaningful and innovative work directly related to the contract to small businesses.
The sixth area of evaluation is regulatory compliance. Here, the evaluator assesses the contractor's compliance with all terms and conditions in the contractor order relating to applicable regulations and codes. Regulations and codes may be of a financial, environmental, labor, or safety nature, and may also include reporting requirements. For example, the evaluator should consider the contractor's compliance with regulations and codes such as labor laws, safety requirements, cost accounting standards, hazardous materials requirements, requirements to use environmentally preferable and energy-efficient products, equal employment opportunity, and prohibitions on trafficking enforcements.
Next we will answer the question, “What does an evaluation consists of,” by examining the parts of the CPARS report card. The first part of an evaluation is the administrative information. Administrative information includes the contractor identification information such as the contractor’s name, address, and number. Other administrative information collected for each evaluation includes contract dollar value, significant contract dates such as award date and completion date, and a list of subcontractors, their DUNs, and a description of work they are performing.
Next the evaluation includes a contract effort description. This description is taken from the contract statement of work or statement of objectives and details the nature of work being performed under the contract. The contract effort description is extremely important to source selection officials because it enables them to determine if the type of effort performed under the contract is similar in scope and therefore relevant to their source selection.
The next part of the evaluation is the ratings. A rating is assigned to each evaluation area using a five level scale, consisting of the adjectives exceptional, very good, satisfactory, marginal, and unsatisfactory. There are definitions for each of these adjectives in the FAR and in the Federal Guidance for CPARS document. It is critical that the evaluator use these definitions when assigning ratings. Following the ratings is the assessing official or evaluator narrative. This part of the evaluation is required for each area which is rated and provides the detail necessary to support the ratings assigned. The evaluator should be extremely thorough in preparing the narrative so as to provide source selection officials with sufficient information to make an informed best value award decision. The evaluation also includes narrative comments from the contractor being evaluated. The contractor has the option to provide a written response to the government’s evaluation and to indicate if they concur or do not concur with the ratings and narratives which describes their performance.
The final piece of the evaluation is the reviewing official comments. The reviewing official is the government official who is a level above the evaluator and whose function is to resolve disputes between the government and contractor regarding the evaluation. Reviewing official’s comments are only required when the contractor indicate they do not concur with the government's evaluation of their performance. The assessing official narratives are the most f important part of the evaluation because they provide source selection officials with the details required to make a best value award decision. Let's review some best practices for submitting a quality evaluation. First, the ratings and narrative should be consistent with the ratings definitions in the FAR and in the Federal Guidance for CPARS documents. The definitions provide criteria for the contractor performance in terms of meeting contractual requirements and providing corrective actions for problems encountered during contract performance. It is extremely important that the evaluation ratings and narratives be consistent with the definitions so that source selection officials can be assured that all evaluators are using the same grading scale when reviewing numerous valuations. Next it is critical that the ratings assigned be supported by objective evidence and that objective evidence be described in the assessing official narrative. For example, the evaluator should consider evidence contained in status, progress, production, and management reviews, earned value management data, cost and schedule metrics, technical reviews, quality assurance evaluations, earned contracted incentives and award fee determinations, subcontract reports, and records of safety and labor standard compliance. The use of objective evidence provide source selection officials with a greater degree of confidence that the evaluator has prepared a thorough and fair performance evaluation. Another best practice is to address the benefit or impact of the contractor's performance to the government. For example, if the contractor exceeded contract requirements in terms of quality, the narrative should describe how the higher-quality good or service provided better enabled the agency to meet its mission or increase customer satisfaction. Conversely, if the contractor did not meet the quality requirements of the contract, the narrative should describe the negative impact to the agency's ability to perform its mission. A well-written and valuation should detail the contractor's strengths and weaknesses and should also take into account any government role in the contractor's inability to meet contract requirements. For instance, if the government was late in providing government furnished information that was critical for the contractor to successfully perform, and then the contractor was subsequently late in delivering, the government should take that fact into account when rating the contractor in the scheduling area and should describe those circumstances in the supporting narrative. In addition, a quality narrative should contain objective statements and be devoid of personal statements and conjecture.
Next, let's look at some upcoming improvements for CPARS. Currently, CPARS contain separate modules for the evaluation architect engineer and construction contracts. These modules, the Architect Engineer Contract Administration Support System, or ACASS, and the Construction Contractor Appraisal Support System, or CCASS will be consolidated into the overall CPARS software application. The consolidation will result in the use of a single evaluation form and single workflow for all contractor past performance evaluations no matter the business sector. The consolidated or merged software will be deployed on July 1, 2014.
PPIRS will also be undergoing some upcoming improvements. First, an improved metric display will be added to provide better search and display capabilities for more efficient access to relevant reports. In addition, PPIRS will be enhanced to include an ad hoc reporting feature to provide the ability for source selection officials to tailor reports to best meet their needs. Both of these improvements will be available in December 2014.
There are many resources available online to assist you in using CPARS and PPIRS. First let's look at some of the resources available on the CPARS website at https://www.cpars.gov. The website contains a training link where you will find access to instructor-led online training, automated training, and on-site training when available. Classes are free and anyone who is new to CPARS or is looking for a refresher is encouraged to sign up for a class.
Next, the CPARS website contains a guidance link where you can find the federal CPARS guidance document, the CPARS user manual, and several Office of Federal Procurement Policy, OFPP memos. The guidance link is a great place to look it you have questions about the CPARS reporting requirements, user roles, workflow, or software. This screenshot of the CPARS homepage highlights both the guidance and the training links.
Next, let's take a look at some of the resources on the PPIRS website at https://www.ppirs.gov. First, there is the training link where you can sign up to take online instructor-led training, whether you are new to using PPIRS or simply looking for a refresher, taking a training class is an excellent way to get started. The PPIRS reference links contains both the user manual which includes how to operate the software and a link to information regarding the PPIRS compliance reports and metrics. Lastly, the guidance link provides an OFPP memo regarding improving the collection and use of contractor performance and integrity information. This screenshot of the PPIRS homepage highlights the guidance, reference, and training links.
We will now conclude with point of contact information for the CPARS and PPIRS helpdesk. The help desk is available by phone at 207-438-1690, or for Department of Defense employees, DSN 684-1690. The helpdesk can also be reached by e-mail at webptsmh@navy.mil. Helpdesk support is available from Monday through Friday from 6:30 a.m. until 6:00 p.m. Eastern Time. The help desk provides excellent support for all types of questions and is a ready resource to assist you in navigating the contractor performance evaluation process.
LF: You will now hear from agency acquisition leaders that have made some great achievements in this area, such as the establishment of sound contract management policies and procedures, that establish clear roles and responsibilities for their acquisition workforce in this process. You will also hear them talk about their enhanced management and oversight and improved past performance reporting compliance strategies. Enhanced training tactics also were established to ensure the workforce were trained in this area. And you will also hear them talk about many more practices they have used to improve their reporting compliance as well as the quality of the information in the system. We are very appreciate of them taking time to share their best practices that they are using to emphasize the importance of this function to their acquisition community and to improve reporting compliance in the timeliness and quality of the information reported.
Richard Ginman (RG): Hello, I am Dick Ginman and I am the Director of Defense Procurement and Acquisition Policy. I have been asked to speak about how the Department of Defense has approached accountability for past performance. Several years ago, I testified before the Commission on Wartime Contracting. One of the issues they addressed was past performance. It wasn't a pretty picture. At the time, DoD's collection of data was below 50%. But over the past several years we have moved our past performance to over 83% and we plan to be above 90% this year. So how have I done it? How have we done it? I will touch on three areas: roles and responsibilities, collection, and usage. We have emphasized the importance of past performance through training, improving our documentation, and tools so that individuals understand their roles and responsibilities related to past performance information.
First, training. The Defense Acquisition University, DAU, has developed six courses aimed at addressing past performance. One, a continuous learning course, CLC, focuses expressly on past performance information and is targeted at contracting officers. Another is directed at contracting officer representatives, or CORs, with a mission focus and may be used to meet COR certification requirements. We also have two in-residence courses for CORs. One covers the broad responsibilities of the COR and the other is focused on COR responsibilities in a contingency or war fighting environment. We have a more advanced contingency COR course for those with broader, more complex responsibilities. Finally, we also have a course on source selection and administration of service contracts that focuses, among other things, on the use of past performance information in source selections in its collection and service contracts. In addition to the DAU courses, we use workshops, seminars, and conferences as opportunities to do training on the importance of past performance from both a collection and use perspective.
From a policy perspective, we have reworked what we call procedures, guidance, and information, or PGI for short. PGI is a part of the Defense Federal Acquisition Regulations supplement, or DFARS. In it we discussed responsibility determinations prior to award and the use of FAPIIS, Federal Awardee Performance and Integrity Information System and SAM, the System for Award Management to gather information to use in these determinations. We also wrote a DoD COR handbook that fits in the pocket of a camouflaged uniform and have updated it several times, most recently in 2012. In it, we stress the COR's responsibility for ensuring services and supplies conform to quality and performance requirements of the contract. The contract quality surveillance is an essential COR activity that CORs are responsible for input to CPARS and that CORs must continually monitor performance. We also developed a tool that contracting officers can use to keep track of CORs and have mandated its use throughout the department. The COR tracking tool, or CORTT, is web-based and tracks the appointment and management of CORs. It keeps track of training and required monthly status reports. The contracting officer can easily determine whether or not reports are being done on a timely basis. Training, documentation, and tools though, are not enough. Program managers, CORs, and contracting officers must report past performance information. OFPP has issued two memorandum, one in July 2009, and the other in January 2011, to focus on improving the collection of past performance information. The Undersecretary of Defense for Acquisition Technology and Logistics issued a memorandum in November 2011 that made clear CPARS reporting is a shared responsibility, of program managers, requirements offices, and contracting personnel. Past performance reporting only works when it is viewed as a priority by leadership not only for timeliness of the input but also the quality of the report. With the issuance of this memorandum, my office began reporting quarterly to senior leadership how each service and agency within the department was doing reporting past performance information. With the increased visibility at the most senior levels of the department, our timeliness of reports has increased each quarter for the past three years. In addition to the quarterly reporting, past performance is discussed as an agenda item at the Business Senior Integration Group, or BSIG meetings chaired by the Undersecretary Acquisition Technology on Logistics.
Beyond CPARS data reporting, the department also collects through automated systems quality and timeliness statistics on the large number of spare part procurements and centrally stores the data so all services and agencies can use it. Collecting past performance data is only valuable if it is used. Past performance is a mandatory element in any source selection evaluation unless specifically waived by the contracting officer. CPARS data is retrieved by contracting officers for use in source selection evaluations. Additionally, PPIRS-SR, the Past Performance Information Retrieval System -Statistical Reporting is available for use between the use the higher threshold established by DoD for past performance collection and the need for past performance data for lower dollar item procurements. PPIRS-SR generates past performance ratings based on objective data about delivery and quality on current and recent contracts. It grades each supplier's performance by federal supply group and federal supply code. Contractors are assigned a color rating that depicts quality of past performance and a numeric indicator representing their on-time delivery performance. The defense logistics agency uses this data and automatic contractor awards system that does over 3000 transactions daily and helps ensure we only contract with responsible contractors. We also use quality performance data collected through GIDEP, The Government and Industry Data Exchange Program and PDQRS, the product quality deficiency report system, to help the department identify and resolve supply-chain quality issues.
As we look to the future, we look to plan to add information on counterfeit material receipts, customs reporting on import problems, and data from other systems that identify waste, fraud, or abuse by contractors. Thank you for this opportunity to talk about past performance information with you today.
William McNally (WM): Hello, my name is Bill McNally, AA for Procurement for NASA. I want to cover two important areas on past performance. What I will talk about is first the collection of past performance, how we do that at NASA and how we populate the CPARS system, and secondly, I will talk about in more depth how we use past performance, how we use that information in the data system in our source selections. Then I will wrap up with a few policy updates on what is being looked at in the FAR as it relates to past performance.
Our past performance policy is to collect information through the CPARS systems which we have gone through a transition. We used to have our own system at NASA, the PPIRS system, so we have adjusted to start utilizing, not a DoD, but a federal-wide system on past performance. The key thing there is to make sure that when contracts are over, that we collect the information from our contracting officer and contracting officer reps, everybody involved in the acquisition, to give us information regarding the performance of that contractor. Many of our contracts are more than one year, so what we do, at each year period, we collect past performance information of that contractor, so it’s really critical that we go out there and do timely and accurate past performance information. Of course, we let the contractor see our assessment, give us a chance to give an update, and one of the things I will be talking about later is a policy update to shorten that time period between our assessment and the feedback we get from industry.
What I really want to do though is spend time on what I call probably the most critical part of past performance; why do we collect past performance information? Well we want to use it to gauge the confidence of the contractors that we are doing source selections. At NASA, most of our source selections, there are three factors that we use. One is mission suitability, where we look at the technical approach, the management approach of the contractor, how are they going to do the job that we have in our solicitation. The second part is price. In some cases, we look for reasonableness or we do a realistic look at price when we are not doing firm fixed price contracts. The last piece, we are looking at past performance. There, we are looking at what is our confidence rating of the vendor? Again, mission suitability, how they're going to do the work, price, what they are going to charge us, and third, what is our confidence that they will actually do the work that they will be selected on?
In the past performance assessment, we utilized a SEB, Source Selection Evaluation Board, and we have voting members there, and we have folks who are involved in a particular area, functional areas. We will have a group that actually works on the source selection just on the past performance. They are looking at what they get from the contractor as far as what is submitted but they also go look at what is in the database, the CPARS database. One of the key aspects is to make sure we are looking at the relevancy of the source selection informationSo what does relevancy really mean? What relevancy really means is that if I have a requirement for system engineering support, then I want to look at the contractors, have they done system engineering support on other contracts? That is a relevancy in a type of work. Then I want to say, if my requirement is $100 million a year, I want to see a contractor’s past performance in that dollar range Other things I may look at is if I have a subcontracting plan for small business. I will look at how well a contractor performed in meeting small business subcontracting goals. So we look at the requirement that we are putting out in the solicitation, and then we are looking at to match up the relevancy in our past performance assessments. So when we finish doing that, then we are going to go and look at their actual performance. There, we put the two together to come up with these areas that I listed here that are our scores. If a contractor is at a very high level of confidence which is our highest score, that means they have very relevant past performance information on the work that matches my solicitation and that their performance was excellent in CPARS. You have to have both matches to get that kind of score. Of course, it goes all the way down to a very low level of confidence. The contractor may not have relevant work. But in most cases, their performance on those contracts were not very good, so we rated them at a very low level of confidence. We do have a neutral rating which is not used a lot, and that is where the contractor has no past performance information, and so we do not want to rate them negatively or positively. We put them down as neutral.
So what we have is the SEB voting members who were assisted by other members who go look at a lot of data. We look at the data that is submitted by the offers, their prime contracts, but also the major subcontracts that are being proposed. So we look at the past performance not only of the offeror who is a prime but all the major subcontractors as well. We take a look at the data, but then we also look at the database in the CPARS. It is really important to understand, an offeror is going to give you, of course, their best-performing contracts when they submit. Here is the contract that we want you to look at that is relevant. And we will look at that, but we need to do our own check in the database. So going back to the beginning, that is why it is important that you populate with your contracts the past performance information. Because that will help NASA and other agencies in their source selections.
I covered the collection. I have covered the use insource selections. So here are some policy updates that are coming very shortly. One is we are changing the FAR to change from the 30-day time frame where a vendor can come back for comments and rebuttals on the past performance to 14 days. We want to shorten that process down. Again, we want to populate the database as quickly as possible. That is the other thing we have in this, within the 14 days, the CPARS assessment will be in the database. The second update is to enhance our past performance information , so we're going to put in the architect engineering contract administration support system information and the construction contract appraisal support system. Again, integrating past performance information into one system. Again, what I would like to do is thank you all who are watching this. Thank you for your support in Federal acquisition, the support you provide the mission and needs of your agency. Again, I applaud you and thank you.
JW: Thank you, Bill, for joining us and discussing what NASA is doing to improve reporting compliance and how you are effectively using past performance information in the source selection process. Now I would like to ask you a couple questions about past performance reporting compliance in terms of what you guys are doing to improve your reporting goals. NASA has improved its reporting compliance and is now at 75% reporting compliance. Can you share with us your performance metrics that you are tracking within your agency and talk briefly about how you communicate progress of this acquisition function to your acquisition managers and staff within your agency?
WM: Yes, first of all, one of the things we do is we go out to each buying center and we do a review of their management systems. One of the things we look at is their past performance. Do they do it in a timely manner? Do they actually write something that is legible and understandable? So we are looking at compliance, but we're also looking at the quality. After that review -- and that is one of the areas, so a lot of my centers are still not doing it timely. 75% is OK, but it is not good enough. So I then discuss it with the center director. Not the head of the buying activity, but the head of the contracting activity. This center director at NASA is the top official at that center. I explain to them as far as where they need to improve in the area of past performance and some other areas, and then I give them six months for corrective action. Last week I had all the procurement officers for a leadership meeting and one of the areas we talked about was past performance. We will probably be putting out a memo for the NASA administrators to sign out, again, to cover the importance of past performance and to get our numbers even higher.
JW: That’s great to hear Bill. You also mentioned that you want to improve reporting compliance, not just in the area of timeliness, but also in the area of quality. I heard you stress that throughout the presentation. Can you talk a little bit more about what you're doing to improve the quality of the information in the reports, since the information in these reports is really helpful and can be useful to the source selection team as they evaluate past performance?
WM: Right, again, what we do when we do our procurement management reviews, we look at how well they write, but the other thing we're focusing on is also in the RFPs, so for instance if I'm asking for a transportation system to carry astronauts to the International Space Station, there are not a lot of companies with that relevant experience. So I do not break it down that specific, but I will look at the past performance of vendors that have built a major system. So that way I am not trying to get too unique because again, I do not want to get someone who is neutral. I want to be able to look at someone that has either favorable or non-favorable past performance in an area that is very much similar to what I am buying. Again, we go in and look at the quality of it. The centers have to do a self-assessment. One of the areas they have to do a self-assessment is what they are doing to improve their past performance information.
JW: That is good to hear, Bill. As with all the agencies presenting today in this seminar, they have all taken a top-down management approach to improving reporting compliance and the quality of the information in the system. So it was really great to hear the information and the best practices that NASA is implementing within its agency to improve its quality and timely reporting of past performance information. Thank you so much for joining us today, and we look forward to more information from you in this area. Thank you.
Laura Aletta (LA): Hello, I am Laura Aletta, the Executive Director for Procurement Policy and Oversight in the Office of the Chief Procurement Officer of the Department of Homeland Security. I would like to thank the Office of Federal Procurement Policy and the Federal Acquisition Institute for giving us all the opportunity to share what we're doing to improve the collection and quality of past performance information. I am looking forward to hearing how others have approached the challenge and hope to adopt tools and practices to take back to DHS. I remember being a contracting officer looking for past performance information to inform a selection decision. It was always disappointing not to find recent or relevant evaluations, but even more disappointing when the evaluations I found were too vague, sometimes a single sentence, to be useful for their intended purpose.
When OFPP issued the agency's goals in March 2013, we took a three pronged approach to improving our performance on this metric. We took a top-down approach, starting with a leadership commitment. And then accountability through internal controls. And then we focused on getting the communication, policy, training, and tools out to the acquisition workforce to help them meet this challenge.
About a month after OFPP's memo issuing the goals, one of our four undersecretaries at DHS, the Under Secretary for Management, issued a memorandum to the component acquisition executives who are the most closely associated with the programs and to the heads of contracting activity. In this memo, he identified discrete requirements to reinvigorate the collection and quality of past performance information, including requiring that the Office of the Chief Procurement Officer brief the Heads of Contracting Activity Council, the Component Acquisition Executive Council, and the Component Acquisition Executive Staff Forum on evaluation of contractor performance requirements. Each DHS component was to host a day of emphasis during which operational organizations would focus, with support from headquarters, including face to face training, on registering and completing performance evaluations as a team. The chief procurement officer was to ensure that annual gold letters were issued to the HCA's to include the targets for past performance evaluations and that they would be included in performance plans for all contracting personnel. HCA's had to consider whether a required evaluation had been completed before they would process and exercise, an option, or process follow-on requirements. Next, the chief procurement officer included the collection and quality of performance evaluations as a key initiative in the strategic plan, establishing a performance metric and goals to be monitored, along with other key metrics focused on achieving quality contracting.
By incorporating the collection and quality of performance evaluations into our strategic plan, we ensured accountability through internal controls. These include issuing the goal letter to each component, letting them know the goals to which they would be held accountable, ensuring that progress towards performance evaluations would be monitored quarterly. Incorporating the collection of performance evaluations into the formal procurement health assessment, which is conducted by the Chief Procurement Officer with each HCA biannually, and recording the outcomes of the procurement health assessment to the individuals response for the performance appraisal for the HCA. We also issued an annual progress report in which we basically take accountability for all of the performance metrics and our procurement health assessment. This is done every year. Finally, we did oversight reviews, sending reminders and emphasizing the importance of the goals.
The third prong to our approach began with communications. We used different communication mechanisms, just as you do. For instance, those directed to the heads of contracting activity and those directed to their acquisition policy representatives. However, I think it is important to communicate directly with the acquisition workforce, as well, rather than relying on already busy components to get the message out. As a result, we use things like "did you know?" communications a more informal tool that goes directly to our 1102 community to make sure the message is getting to those who need it the most. We also think it is important to stop to recognize improvement on the way and you can do this by recognizing the most improved organization or the highest quality organization, and of course, we also take that opportunity to identify areas for improvement.
As for training, in Fiscal Year 2013 we provided face to face training for over 4000 employees at DHS, representing not just 1102s but others in the workforce who must support contractor performance evaluation. We hosted and supported “days of emphasis” where teams would receive training and ensure all backlog contracts were registered, and then complete the assessment. A day completely dedicated to completing contractor performance evaluations. We also provided tools, such as quality checklists that included good sample narratives to help our acquisition workforce ensure their contractor performance evaluations would be useful. Finally, we supported all those acquisition workforce members in their efforts through both policy and systems support.
Of course, we issued policy for both our 1102s and non-1102s, including the Contracting Office Representative guide which provides information to the CORs on how they support the contractor performance evaluations. Of course, we have more work to do to ensure that our contractor performance evaluations are as helpful as possible to source selection teams -- to ensure that the United States contracts are with the best contractors contractor with the highest levels of integrity in business ethics. Thank you, and I look forward to working with you on improving the collection and quality of contractor performance evaluations.
John Bashista (JB): Hello, everybody. I am John Bashista and I am Director of the Office of Acquisition Management at the United States Environmental Protection Agency. I am here to talk about EPA's best practices and improving our contract performance assessment reviews and our compliance with both the reporting and the quality of our contractor performance reviews. I’ve been in this profession for almost 30 years, and I began at the National Aeronautics and Space Administration as a contract specialist and contracting officer. So I have a great deal of empathy for all of the functions that the contracting officer has to perform. As a matter of fact, I went to the FAR and identified 82 contract administration functions that the contracting officer has to perform.
But why is it important that we effectively report on contractor performance? Well, one is that we want to make sure that the taxpayers’ dollars are being spent on contractors, both current and future contractors, who are high-performing and who are providing quality goods and services to the federal government. We also want to make sure that we're taking advantage of the opportunity to give our contractors feedback on their performance so they can improve and become better contractors in the future. As you can see from this slide, we better than doubled our compliance rates since October of 2012. I will get into some of the management initiatives that we have undertaken to do that. But meeting this, and I am sure everybody watching this video is encountering challenges along the way, and in my experience and I am sure many of yours, I will categorize our challenges in two primary areas. One is a lack of management focus on compliance and accountability. The other is the need to write better performance-based contracts so that we have better performance measures against which we are credibly and responsibly assessing our contractors.
What are some of the EPA management strategies that we are employing to achieve the improvements that we have achieved? I think one of the most important things we can do is create awareness, not just with the acquisition workforce and the people that support them, by them I mean the contracting officers, the COR's, program managers, but I'm talking about the senior managers within the agency, people to whom those people report. We need to make sure that they understand and appreciate the roles and responsibilities of the people to whom we are delegating those authorities to and what the consequences are for people not complying with those requirements. The other thing we have done is we're actually dedicating staff to this. We have designated a lead and a backup in my organization and our policy organization. We have identified a focal point at each of our 14 operational contracting offices within EPA. Lastly and probably most importantly, what we have done is we have created a robust policy and guidance framework, as well as integrated compliance and oversight with our performance management system. I will talk more about that in these other slides. I will talk a little bit more about the strategies that we are employing. I mentioned that we have established a lead and backup focal point for the agency to monitor the agency's compliance, and we have established a focal point in each of our 14 contracting activities within EPA. That group meets on a quarterly basis at a minimum, and it is an opportunity for those individuals to talk about the challenges they are facing within their organization and with their program customers. It is an opportunity for them to talk about best practices on how their managers are implementing the requirements to comply, which include things like stand down days. It’s also an opportunity… Most recently, we brought in a NAVSEA to give our folks briefings and a train-the-trainers concept, and a training that is available online for writing quality narratives for best performance. It was an opportunity to provide personalized training, for our folks to ask questions and get answers, and those individuals will now go out and provide personalized training to the acquisition community at EPA. NAVSEA also recently came in and gave our folks a briefing on the changes that are forthcoming this month in integrating CPARS with the separate past performance systems that have been maintained for A&E and for construction contracting. It is also an opportunity for the -- I refer to this focal point group and to my lead as kind of the CPARS help desk. NAVSEA, I’m sure, gets inundated by every agency for every question, and this is an opportunity where these focal points can filter those questions. We can bring in an EPA consolidated question to NAVSEA. It also gives us some visibility into some of the common issues we might encounter across the agency. This group also does monthly compliance monitoring. Reporting from that not only is to the focal points, but it is also to the managers at each of our contracting activities, and the report also comes to me so I can see how each organization is doing with respect to compliance. My staff also conducts one-on-one engagements. So if there is an organization that is struggling with compliance, they will reach out and engage those folks directly and actually be able to share best practices, provide technical assistance, or raise issues to my attention where I may have to take some action with some senior managers in an organization or region.
Again, we are building all of this around our performance management system and that is really intended to build knowledge management and I’ll talk to that a little more as we go along. So we are required to ensure that not only are we complying with the requirements for the contracts that are required to report past performance, but we also need to make sure we're actually doing quality. We do not want to just check the block on compliance and have information and data in the system that is not useful to anyone. Last September, we conducted our first quality assessment. We took a random sample of 30% of all the past performance reports that were in our system, and we did a quality review. We determined that we were actually doing a pretty good job. 78% of those reports actually contain very high quality and useful information. Again, our goal is always 100%. So we are striving to get there this year.
As I mentioned, our agency lead performs annual quality reviews. Again, what we do is, at a minimum, we will use the 25% random sample, but I mentioned that we also created this within our organization's performance management program; part of that program encompasses a project management assessment program. Most of you folks that have been in this profession for quite a while think about this as part of self-assessment or procurement management reviews. We have both. We have specific criteria against which organizations are required on an annual basis to assess themselves in terms of pre-award, post award, contract management systems, and we have specific criteria built around contractor past performance reporting, and do an internal assessment of the quality of those reports. Once every three years, we have a peer review team and a group of experienced contract folks that supplement that team that review each contracting activity once every three years, at a minimum, on those same criteria. We have integrated them both. Not only do we do an annual but we also do a continuous, ongoing assessment as part of a larger contract management program. And I will tell you that we have recently conducted a review of one of our regions and they are 80% compliant and close to 100% on quality on their reviews. I think we are really turning the corner and making significant progress. Again, my superstar who is managing this program is Staci Ramrakha. Her information is right there and I encourage you to give her a call if you need any questions answered or if we can provide any assistance to you. Thanks.
Iris Cooper (IC): Hi, I am Iris Cooper, I am the Senior Procurement Executive for the Department of the Treasury. Like my colleague, John, I am a contracting professional by trade. I have spent over 25 years being a contracting officer and kind of working my way up. So I feel your pain. When it comes to talking about past performance, I think for most contracting professionals, that is about as exciting as talking about contract closeout. It is one of the things we have to do and it is critical that we do it right. So just complying to get the numbers is not good enough. It is driving the whole quality aspect of past performance reporting. I will talk a little bit about contractor performance information -- why we should do it and why it matters to us. What are the challenges to getting to compliance, especially with the quality piece? Strategic management and how we're dealing with that at the Department of the Treasury. And then the quality of the past performance information, some steps we have taken in Treasury to implement that piece.
Obviously, Federal Acquisition Regulation compels us to monitor contractor past performance. We must monitor performance evaluation requirements, I think sometimes if we would write better requirements documents, we would probably have better past performance documentation. But it is all interconnected and we need to focus on that end as well. Agencies are required to use the Contractor Performance Assessment Reporting System, CPARS, and Past Performance Information Retrieval System, PPIRS, to measure the quality and timely reporting of past performance information. It is required for each contractor order above the Simplified Acquisition Threshold with some exceptions.
So why does it matter? I think past performance is a good indicator of future performance. Reliable past performance information supports source selections. I have used it successfully in major source selections, and it is absolutely critical for us to consider that when we do competitive awards. Even in a single source award, it is critical information to have. The better the quality, the more useful during a source selection. In the current budget environment, I think it is essential that we award to absolutely the best contractors available that deliver on time and of high quality. Really, when you think about it, those of us who use Angie's list, you are not going to get the services of a plumber who is not good. You're going to check the rating and make sure you get the best out of it. This is no different, the government should get the same and we have that responsibility.
The challenge to achieving not only the compliance ratings but also the quality piece is acquisition is a team sport. The contracting officer is largely held responsible, unless the agency has implemented different regulations, but it is a shared responsibility by the COR, the program manager and the contracting officer. It is a team sport; we need to play together to get right. The quality piece is often lacking because people are overworked. This is not the highest priority item on their desks. If you give a satisfactory rating, you are done. You do not have to justify a whole lot. It gets you to compliance, it does not get you to the quality piece. And I think there is also sometimes a sentiment of let's avoid a confrontation with the contractor. If there is a negative past performance, it causes extra work and there is a back-and-forth until you resolve the issue. It is absolutely critical you take on that responsibility. As 1102s especially, as contracting officers, it is a responsibility. It is our value proposition in this process as well. Without quality in the past performance rating, we actually allow poorly performing contractors to continue to exist in the federal space, and we need to clearly resolve this. I actually encourage our contracting officers outside just the regular reporting cycle to pick up the phone and call the company, especially if you deal with some of the smaller companies who are new to government and say, how is it going, from their perspective, not just from our perspective. I think if you have that kind of feedback mechanism, most contractors want to do a fabulous job. They want that good rating. It is a great way of opening the dialogue because if something goes wrong, do not wait for the formal feedback peace. Engage and try to resolve, because that works best for everybody. When you think about it, we take time to rate a restaurant on Yelp, so we can certainly rate a contractor in CPARS. It is really not a whole lot different.
So past performance compliance -- one thing we have done at Treasury is we actually looked at our internal policy and said, how can we improve what we're doing and put a better structure into place? We did not only focus on just the completion of the past performance information, but we also looked at how to drive the quality component of what we are doing. The strategic management I think is critical. If senior management pays attention, everybody pays attention. I know I pay attention to what my boss wants, and I am sure it is the same for most of us. Senior leadership accountability, we are organized into bureaus, and the bureau chief is responsible for contracting. This is actually part of their performance rating. It is something we address on a monthly basis in our Treasury Acquisition Council meetings. We send out weekly goals as we're inching upward. We're getting closer to the 80%, which is great. I have a staff member on my staff that does the reporting and sends it out, and then I add the encouragement, you can see the bureaus that are making rapid progress, and putting attention to it. We do report this to our senior leadership. It is part of something that Deputy Secretary of the Treasury sees as part of our performance reviews. I think it is important, one of the measurements that is paid attention to at the highest levels. So I think we're getting there.
In terms of compliance, we have absolutely made progress. I cannot claim success because I have only been there for five months. But what we have done in the five months has been significant, and the department has done a great job driving this. We have looked at how to best improve the quality component, and we're definitely not there yet. EPA definitely has some advantages. You guys are ahead of the game, so I can learn something here. We're pulling a sampling each month of the past performance entries, and we have developed a scoring system. We look at this and report out so they know how we're doing. I would say we definitely have room for improvement, because it is much easier to put it fully aside and not worry about it. And we’re kind of driving the more honest reporting. If the contractor is really good, they deserve the extra credit. If there were deficiencies, we must justify that, as well. We provide training to the bureaus at request on a regular basis. It is one of the things that is mandated that they take. So the whole evaluation and monitoring concept when we do on-site assessments, we also pay attention to the past performance information and the recording of it. I think we are encouraging them to focus on it early in the year so it does not get overcome by events, which is always a problem in our area. I think we are seeing the improvements we want. Maybe not as quickly as we want, but I think we are getting there.
So the quality of the past performance information, just to sum it up. It is great if you have the compliance rate. We're close to the 80% now. Now the heavy drive has to be on the quality input. We're going to continue that push next year. We will probably increase the sample size and pay more attention to it. I think we are seeing the benefit. Also, we are going to continue our training efforts with our folks and increase the exchange they routinely have with the vendor community so it is not just left up to the formal process but we are really increasing quality throughout.
So if you have any questions regarding Treasury's measures in the past performance area, feel free to contact me. I am at iris.cooper@treasury.gov. Feel free to send me an e-mail and reach out to us. We will be happy to help.
JW: Thank you, John and Iris for providing such great insight into your leadership tactics that you are using to improve reporting compliance in your agencies. Now I have a few questions about what you're doing to improve reporting compliance.
In particular, as an acquisition leader within your agency, you have demonstrated great leadership and taken great interest in ensuring that this function is properly implemented and monitored throughout your agency. What was the main step you would say really helped improve your agency's reporting compliance.
IC: It was very important that I stepped up and paid attention to it. It is part of all of our performance agreements and it part of our ProcureStats and it gets reported up and looked at regularly. So the focal point on my team sends the information, but I pay attention to it and I will follow up. So that makes my bureau leaders follow up, as well.
JW: That is great to hear. John?
JB: I touched on it, and Iris touched on it. I call these types of things -- how do you put stuff on people's radar screens? These are the things, as we all know, people tend to focus largely on the placement activities, the awarding of contracts. It is all those responsibilities we have to do after we award the contract that, as Iris mentioned, that is probably the most important piece. Are we getting what we bargained for? Are we getting what we paid for? I think it’s two things, really: the awareness I talked about with the agency senior managers; it is the understanding, but it is more importantly giving people the tool to manage it and make sure it is on people's radar screens. Establishing performance measures, monitoring monthly and quarterly reporting. Again, the accountability piece to it.
JW: Great to hear. You also talked about quality control and how you are making sure that quality is included in your reports. What are you doing to ensure accountability of this function in your acquisition workforce, making certain that acquisition officials, responsible for documenting performance, provide meaningful, useful input to the contracting officer or into the CPARS database about the contractor's performance?
IC: Again, we have started taking this role to actually pull a sampling of what is in the database and look at it objectively. Is this really helpful? Is this useful information? We have started reporting this at our monthly Treasury Acquisition Council meetings. So there is an awareness now. Again, you put it on people's radar screens, you get what you inspect. We're nowhere close to where EPA is in terms of the quality piece, but we're certainly driving towards that this this fiscal year and the next fiscal year.
JW: That’s great to hear. And John, do you want to elaborate on what Iris said about quality control?
JB: What I consider accountability, again, I do not look at it as a need to take the hammer to people. I do not think people don’t comply on purpose. It is because we do not have a management focus on it. I think the things that we're doing with respect to the tools, the training, the guidance, dedicated staff, and we're managing and monitoring it; it is getting it on people's radar screens. People appreciate it, and our compliance is way up. With respect to accountability, ultimately though, as our contract management system…as I talked about there… delegations of authorities to contracting activities, individual warrant authorities, COR warrant authorities, those are all conditioned on people’s compliance with this. So, giving them the tools and making sure we are monitoring and tracking it, making sure we are identifying the challenges and overcoming that is one piece of it. To the extent that people are not doing what they need to do with those tools, then there is always that piece of it, too.
JW: Great, it is good to hear your leadership on this particular effort. Let's also talk a little bit more about past performance reporting compliance, just to hear a little bit more about what you're doing to incentivize your contracting workforce. Even though past performance reporting is a required contract management function, contract administration is often the last function to complete. What do you do -- do you do anything extra to incentivize or motivate your contracting workforce to perform this function?
IC: I think it is more motivational because I come from the contracting profession. I can stand up there because I know how that feels. It’s like John said, we're driving to award and then we forget that this is when it really starts. I encourage my CO's to really pick up the phone, call the contractor, and ask how it is going. We do not have that interface a lot. It is more to our technical people. I think it’s important especially for some newer companies who needs to get that feedback. All of us want to be successful. I think we're all going to succeed when the contractor delivers quality service or goods. So that early outreach can make the formalized process so much easier. I think that is my motivation. Pick up the phone, make that call, it will pay for itself in the long run.
JW: That’s great. John what about you?
JB: We all know the acquisition community is a tightknit community. I think it is growing, at least I see it in my agency. There is a sense of a growing obligation to make sure that what we are putting in the system is useful information for others. Certainly, we want to get that. The more that we are emphasizing the need to use this information, particularly for source selection, and Iris talked about that in her briefing, the more that we are looking for quality, the more we want to rely on it, the more the professionalism of our people are coming through and really wanting to do the same. I see that both on the contracting office side as well as in the COR community. That is incentive enough, people wanting to do the right thing and wanting to do a good job and I see that at EPA. I know my folks are seeing at it from stuff they’re looking at.
JW: That is great to hear. Thank you both for joining us today.
IC and JB: Thank you.
JW: You have heard from a number of agencies about their best practices. I also want to share information from the Department of Energy and Department of Education, some of the practices that they're using to improve their reporting compliance.
First, I will talk about the Department of Education. The Department of Education improved their reporting compliance to 82.35%. With that improvement, we asked the Department of Education to share steps they are taking to improve reporting compliance within their agency. They shared the following steps -- one of the steps they have implemented is that they are making sure that grant contract specialists have access to CPARS as officials and representatives along with the Contracting Officer Representative, and they also train staff on entering quality past performance information. They include CPARS compliance in staff performance plans. They also report weekly on the status of CPARS' completion. The Department of Education also ensures that the CORs and contracting officers have a mutual understanding of monitoring responsibilities, and they monitor the fulfillment of these obligations.
They have also structured contracting functions to encourage full awareness and establish communication channels within their agency. The Department of Education also ensures that the system includes accurate documentation of contractors' information. They review performance information for completeness and accuracy and make any necessary corrections.
Now I would like to share with you the information that the Department of Energy shared with us that they're using to improve their reporting compliance. Unlike most federal agencies that obligate their procurement budgets across a large number of contracts, the Department of Energy obligates approximately 85% of its contract dollars on 36 large management and operating, site management and environmental cleanup contracts. The Department of Energy is different from most agencies in that it accomplishes the various missions of its agency contractors rather than through a large federal workforce, supplemented by contract activities. The majority of their 36 contracts are cost type in nature and contain either award fees or incentive fee provisions. A number of the contracts also contain an award term provisions. Given the large dollar values and importance of these contracts, DOE pays close attention to monitoring contractor performance. The use of management and operating contracts unique to DOE allows their agency to have a much closer working relationship with contractors, thereby facilitating communication and partnering to reach common performance goals and objectives. I invite you to review their practices posted on this ALS website so you can read the details of the steps they are taking to make certain that their workforce effectively uses and documents performance information in this performance system.
JW: Today you have heard some really interesting practices today’s agencies are using to improve reporting compliance and information in the system. In summary, agencies have established policies and procedures that demonstrate management’s commitment to this process with many managers conducting frequent meetings, monthly or quarterly, to discuss reporting compliance. They also hold their workforce accountable for performing this function by establishing clear roles and responsibilities for acquisition participants in the source selection process, making sure that past performance information is effectively used and in the contract administration process, making certain that past performance information is documented timely in the past performance systems with helpful information about the contractor’s performance. They also work to ensure that reporting compliance is monitored and measured and evaluation reports are assessed frequently within their agency to ensure that they are not only reporting timely information, but also including quality information in the systems. Many agencies also talked about how they are making sure their workforce is trained in this area. They are also making certain that the workforce is being transparent with the contractor and communicating performance successes and failures, documenting this information in the performance systems in a timely manner so it can be shared quickly with source selection officials.
LF: Thank you for joining today's seminar. Please share the practices you heard and use them appropriately to improve past performance practices within your agency. Our collective attention to this important initiative will improve our acquisition outcomes and deliver more value to the taxpayer. At this time I want to thank the acquisition officials who participated in this seminar to share their best practices. As stewards of the Federal acquisitions system, we are all responsible for ensuring we achieve the best results possible from our contractors. My office will continue to work with your agencies to improve the collection and use of quality and timely performance assessments so that agencies can use this information to make the best decisions possible for the taxpayer. Thank you again.
JA: That was an amazing overview of past performance and how it impacts the acquisition process. We certainly hope you found today’s seminar extremely valuable and useful. Though past performance can come across as a very mundane issue, these presentations serve as a reminder of how vital it is. On behalf of the Federal Acquisition Institute, thank you once again for joining us.
