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CPARS Procedures

Federal Government Contract Attorneys - CPARS

A satisfactory past performance record is increasingly important in today’s competitive marketplace. Historically, the Government maintained several past performance databases – CPARS, ACASS and CCASS.  These databases have now been merged into CPARS - Contractor Performance Assessment Reporting System.  Once past performance evaluations are completed, the Government can retrieve them from another database called the “Past Performance Information Retrieval System (PPIRS).”   The plan is to eventually merge PPIRS into CPARS as well, so there is a single database.

The Government has published the following documents on CPARS:

CPARS GUIDE

CPARS USER MANUAL

This information could make or break a contractor’s chances of future contract awards.  It is therefore important that you know what your rights are if you get an unfavorable past performance evaluation.  Attorneys at our firm can assist in challenging a poor CPARS evaluation.  Please contact us for a free consultation by one of our lawyers.

Past Performance Evaluation Procedures

FAR 42.1503 sets forth the procedures for evaluating past performance and gives the contractor an opportunity to respond.  The following steps must be followed:

1. Unless someone else is designated in the agency procedures, the Contracting Officer is responsible for evaluating past performance.
2. The agency may perform interim evaluations.
3. The evaluation should include a clear non-technical description of the principal purpose of the contract or task order. The evaluation must accurately depict the contractor’s performance. Evaluations based on speculation are improper.
4. Evaluation factors for each assessment shall include, at a minimum, the following:  (i) Technical (quality of product or service); (ii) Cost control (not applicable for firm-fixed-price or fixed-price with economic price adjustment arrangements); (iii) Schedule/timeliness; (iv) Management or business relations; (v) Small business subcontracting (as applicable); and (vi) Other applicable factors.
5. The agency shall promptly provide its evaluation of a contractor's performance, including both negative and positive evaluations. The contractor will receive a CPARS-system generated notification when an evaluation is ready for comment.
6. Contractors shall be given up to 14 calendar days from the date of notification to submit comments, rebutting statements, or additional information. [CPARS Manual says contractors have up to 60 days to respond, but if they do not respond within 14 days, evaluation is sent to PIPRS as “pending” but can still be relied upon in source selection decisions].
7. A person a level above the contracting officer must consider disagreements between the parties regarding the evaluation.
8. The ultimate conclusion on the performance evaluation is a decision of the contracting agency. Copies of the evaluation, contractor response, and review comments, if any, shall be retained as part of the evaluation.
9. The Government then prepares and submits the past performance evaluation electronically in the CPARS. This evaluation, plus any contractor comments, are automatically transmitted to PPIRS.
10. The Government shall use the past performance information in PPIRS that is within three years (six for construction and architect-engineer contracts) of the completion of performance of the evaluated contract or order, and information contained in the Federal Awardee Performance and Integrity Information System (FAPIIS) e.g., terminations for default or cause.