By Gloria Larkin
The U.S. federal government’s Integrated Award Environment (IAE) has completed the merger of the Past Performance Information Retrieval System (PPIRS) with the Contract Performance Assessment Reporting System (CPARS.gov). CPARS now serves as the federal report card system for prime contractors providing services and products to the U.S. federal government.
The IAE is the centralized authoritative source for government contract award data and is merging ten separate contracting data systems under one umbrella.
Government decision-makers now use CPARS to review contractors’ performance under previously awarded contracts. Data points include requirements compliance, meeting deadlines, reporting processes, integrity and business ethics, pricing and invoicing, and customer-service processes. These reviews often contain sensitive information and can also influence new contract awards, therefore, only authorized government personnel have access to these records, along with the specific awardee. No records are available to the general public.
The contracts tracked in CPARS must be prime contracts and fall above the Simplified Acquisition Threshold (now $250,000 base plus option years).
Subcontracts
Subcontracts are not tracked in CPARS, however, the Small Business Administration is considering a process to create a pilot program to provide subcontractor performance ratings. No updates from the SBA regarding the subcontractor program have been posted since April 2018 when the Subcontractor Past Performance Pilot Program was published in the Federal Register.
Agencies are themselves tracked regarding their completion of the individual CPARS, with their compliance percentage being reported annually.
Timeframes
The mandated timeframes for contracting officials to file CPARS reports are as follows. For contracts less than one-year duration, a completed evaluation is due 120 days from contract completion. For multiyear contracts, a completed evaluation is due 485 days from the contract award date and every 365 days thereafter through contract completion. Evaluations are required annually for multi-year contracts as either Interim Reports (those leading up to contract completion) or Final Reports (after completion of work). Government officials can also submit Addendum reports, however these are not required, nor do they affect the compliance metrics.
Data from the legacy PPIRS database has been integrated into the new official system of record, CPARS, for the purpose of simplifying functions such as creating and editing contractor performance and integrity records, changes to administering users and running reports, generating performance records, and viewing or managing performance reports.
Government personnel use CPARS to objectively evaluate the contractor’s performance during and upon completion of a contract and review relevant performance and integrity records before making a new contract award decision.
Contractors can access their own records only; information is not made public regarding these performance reports. Upon review of the relevant reports, contractors can comment on the evaluation and concur with or provide additional information to support or refute a rating.
Responses
After receiving notification of an interim or final CPARS report, a contractor has 14 days to provide responsive comments. On the 15th day the government CPAR and any response from the contractor are automatically transmitted to the reporting database. However, if the contractor disputes the CPAR within the 14 days, a reviewing official (not the contracting officer) will review both the CPAR and contractor response and provide an additional assessment.
CPARS records may be challenged through various entities including the Court of Federal Claims, and competent legal counsel is strongly recommended for such challenges.
Gloria Larkin is President and CEO of TargetGov and a national expert in business development in the government markets. Email glorialarkinTG@targetgov.com, visit www.targetgov.com or call toll-free 1-866-579-1346 x 325 for more information.