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Friday, April 1, 2011

YOUR SMALL BUSINESS FEDERAL GOVERNMENT CONTRACTING PAST PERFORMANCE RECORD

“Relevant information for future source selection purposes, regarding a contractor’s actions under previously awarded contracts. It includes, for example, the contractor’s record of conforming to contract requirements and to standards of good workmanship; the contractor’s record of forecasting and controlling costs; the contractor’s adherence to contract schedules, including the administrative aspects of performance; the contractor’s history of reasonable and cooperative behavior and commitment to customer satisfaction; and generally, the contractor’s business-like concern for the interest of the customer.”

FAR 42.1501


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INTRODUCTION


As a small enterprise enters the government contracting venue, the phrase “Past Performance” almost immediately comes to the fore. When examining government Requests for Proposal (RFP’s) a section of the award criteria is almost always specified for past performance ratings on previous similar government work.

We have discussed meeting the initial past performance challenge for companies new to government contracting in the following discussion:


http://www.smalltofeds.com/2008/07/small-business-government-contracting.html

The primary purpose of past performance evaluations is to ensure that accurate data on contractor performance is current and available for use in source selections. A past performance evaluation report provides a record of a contractor’s performance, both positive and negative, on a given contract during a specified period of time.

This article will focus on accessing your past performance record, and explain how the government rates a contractor’s past performance:

ACCESS

The following is an extract from the Contractor Past Performance Information Retrieval Web Site on obtaining information on your company information there:

http://www.ppirs.gov/ppirsfiles/faqs.htm

“Contractors obtain access to PPIRS through the Central Contractor Registration process. To obtain access, a contractor must enter a Marketing Partner Identification Number (MPIN) in their profile in the Central Contractor Registration system (http://www.ccr.gov/). This can then be used to access their own reports in PPIRS. If they are already registered in CCR, contractors will be asked for their DUNS number and Transaction Partner Identification Number (TPIN) when they update their contractor profile to include the past performance point of contact and MPIN. Contractors should ensure that they know their DUNS number and TPIN number in order to update contact information in their CCR profile. To access information in PPIRS, they log in using their DUNS and MPIN number.

Performance Assessment reports are NOT required on every contract. The government has issued agency guidelines that define when a report card should be completed. Generally report cards are required for all contracts for products or services that are greater than $100,000. However, DOD has been granted a waiver to that requirement (See class deviation 99-O002 of 29 January 1999). Instead, within DOD, they categorize procurements by business sector and dollar value groupings. These are listed in the DOD Guide to Collection and Use of Past Performance Information. A copy of that guide is available at http://www.acq.osd.mil/dpap/Docs/PPI_Guide_2003
.
If you are providing commodities or services in the Systems or Operations Support business sector then a report would be required if the total dollar value of any one contract exceeds $5,000,000. For Services and Information Technology, the threshold is any contract that totals over $1,000,000. For Ship Repair and Overhaul contracts the reporting threshold is $500,000. For Fuels and Healthcare, it is only $100,000. Within DOD, there are also specialized past performance databases for the Construction (CCASS) and Architect-Engineering (ACASS) business sectors. If you are doing business in those specialized business sectors, your past performance information would be in either ACASS or CCASS. For more information ACASS/CCASS, go to https://www.nwp.usace.army.mil/ct/i. Another guide that is applicable to all agencies is the OFPP Best Practices for Collecting and Using Current and Past Performance Information.

We've been collecting report card information for about the past five years. Not all assessing officials have yet gotten into the habit of completing report cards. If one is not completed, it will not be in the PPIRS system. If you know that you have a contract that falls within the reporting limits indicated above, then you should contact that contract's program manager or contracting officer to assure that a report card is completed. By doing that, you will ensure that a record of your performance will be available to source selection officials for consideration in future contract awards.

CCR information is contained in a different database than PPIRS. Currently, the CCR file is updated to PPIRS weekly (usually on Thursday mornings). call our Help Desk at (207) 438-1690 and we will research and help correct a problem.

A report card is not required until at least twelve months have passed since the contract was awarded. So, a report card may not yet be due. Second, the government is allowed an additional period of time for report processing. Even if a contractor has commented on a report card, it still must be processed by the program manager/assessing official and possibly a reviewing official before the completed report is entered into the PPIRS database and made available to source selection officials.

Tip: As a contractor, you do not have to enter any parameters on the “Assessment Reports” selection screen to view all of the information assigned to your DUNS and MPIN number. Just click on “Submit” to view all the PPIRS information for your company. The application has already restricted you to view only PPIRS information assigned to your DUNS and MPIN combination. The filters that are available on the “Assessment Reports” retrieval menu simply allow you to further restrict your view to a defined subset of the information that is available to you.

PPIRS contains all of the records that have been submitted by the contracting official responsible for preparing the report. NIH, NASA and DOD operate systems to track contractor performance. These systems feed into PPIRS. DOD also has specialized databases that track performance on construction (CCASS) and Architect-Engineering (ACASS) contracts. ACASS data is not yet in PPIRS, but plans are underway to make that information available in PPIRS. Use of PPIRS is not mandatory, therefore an agency may track performance using a manual process.”

PAST PERFORMANCE REVIEW CONTENTS BY KEY ASSESSMENT ELEMENT

Below are the key assessment elements required for contractor reviews of major procurement sectors in federal government contracting.

Assessment Elements for the Systems Sector

Technical (Quality of Product) —This element is comprised of an overall rating and six sub elements.


Activity critical to successfully complying with contract requirements must be assessed within
one or more of these sub-elements. The overall rating at the element level is the Program Manager's integrated assessment as to what most accurately depicts the contractor's technical performance or progress toward meeting requirements. It is not a predetermined roll-up of the sub-element assessments.

Product Performance—Assess the achieved product performance relative to performance
parameters required by the contract.

Systems Engineering—Assess the contractor's effort to transform operational needs and
requirements into an integrated system design solution.

Software Engineering—Assess the contractor's success in meeting contract requirements for software development, modification, or maintenance. Results from Software Capability Evaluations (SCEs) (using the Software Engineering Institute {SEI's} Capability Maturity Model {CMM} as a means of measurement), Software Development Capability Evaluations (SDCEs), or similar software assessments may be used as a source of information to support this evaluation.


Logistic Support/Sustainment—Assess the success of the contractor's performance in
accomplishing logistics planning.

Product Assurance—Assess how successfully the contractor meets program quality objectives (e.g., producibility, reliability, maintainability, inspectability, testability, system safety) and controls the overall manufacturing process.

Other Technical Performance—Assess all the other technical activity critical to successful
contract performance. Identify any additional assessment aspects that are unique to the contract or that cannot be captured in another sub-element.

SCHEDULE—Assess the timeliness of the contractor against the completion of the contract, task orders, milestones, delivery schedules, administrative requirements, etc.
 COST CONTROL—(Not required for firm-fixed-price or firm-fixed-price with economic price adjustment contracts.) Assess the contractor's effectiveness in forecasting, managing, and controlling contract cost, including reporting and analyzing variances.
 Management—This element is comprised of an overall rating and three sub-elements. Activity critical to successfully executing the contract must be assessed within one or more of these sub-elements. This overall rating at the element level is the Program Manager's integrated assessment as to what most accurately depicts the contractor's performance in managing the contracted effort. It is not a predetermined roll-up of the sub-element assessments.
 Management Responsiveness—Assess the timeliness, completeness, and quality of problem
identification, corrective action plans, proposal submittals (especially responses to change orders, engineering change proposals, or other undefinitized contract actions), the contractor's history of reasonable and cooperative behavior, effective business relations, and customer satisfaction.

Subcontract Management—Assess the contractor's success with timely award and management of subcontracts, including whether the contractor met or exceeded small business, small disadvantaged business, small business HUBZone, veteran-owned small business, service disabled veteran-owned small business, and women-owned small business participation and subcontracting goals.


Program Management and Other Management—Assess the extent to which the contractor
discharges its responsibility for integration and coordination of all activity needed to execute the contract, identifies and applies resources required to meet schedule requirements, assigns
responsibility for tasks/actions required by contract, and communicates appropriate information to affected program elements in a timely manner. Assess the contractor's risk management practices, especially the ability to identify risks and formulate and implement risk mitigation plans. If applicable, identify and assess any other areas that are unique to the contract or that cannot be captured elsewhere under the Management element.

Assessment Elements for the Services, Information Technology, and Operations Support Sectors
 QUALITY OF PRODUCT OR SERVICE—Assess the contractor's conformance to contract requirements, specifications, quality of software product and development, and standards of good workmanship (e.g., commonly accepted technical, professional, environmental, or safety and health standards).
 SCHEDULE—Assess the contractor’s timeliness against the completion of the contract, task orders, milestones, delivery schedules, and administrative requirements (e.g., efforts that contribute to or effect the schedule variance).

COST CONTROL—(Not required for firm-fixed-price or firm-fixed-price with economic price adjustment contracts.) Assess the contractor's effectiveness in forecasting, managing, and controlling contract cost, including reporting and analyzing variances.
 BUSINESS RELATIONS—Assess the integration and coordination of all activity needed to execute the contract, specifically the timeliness, completeness, and quality of problem identification, corrective action plans, proposal submittals, the contractor's history of reasonable and cooperative behavior, customer satisfaction, timely award and management of subcontracts, and whether the contractor met small business, small disadvantaged business, small business HUBZone, veteran-owned small business, service disabled veteran-owned small business, and women-owned small business participation and subcontracting goals.

MANAGEMENT OF KEY PERSONNEL (for Services and Information Technology business sectors only)—Assess the contractor's performance in selecting, retaining, supporting, and replacing—when necessary—key personnel.


SUMMARY


Regular review of your past performance information system data is vital to your future marketing efforts. Please feel free to download the Guide to the Past Performance Retrieval System in the second, vertical Box Net "References" cube in the left margin of this site.

2 comments:

Anonymous said...

The retention for these records is 6 years after the final evaluation is submitted. Do you know when they run a check on a company, can they see anything older than 6 years?

Ken Larson said...

Anonymous: If the programs are classified the agency will run a check through the investigative services back at least 10 years.

The past performance data base is permanent. The records retention rules these days are getting obsolete, since everything is going paper.

Suffice it to say say the government will go back as far as they feel prudent.