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Shelley Hall << Record >> 32 years in Department of Defense (retired Nov 2015) USAF (AFMC and AFSPC) Held unlimited Contracting Officer’s warrant for 23 years Community Relations and Content Manager for Skyway Expertise in services and supplies, Federal Supply Schedules, pre-and post-award, simplified acquisition to large dollar technically complex source selections, Foreign Military Sales, and commercial and non-commercial << Record >>

Skyway Insight© Webinar Training From Contracting Officers Topic: CPARS Host: Shelley Hall 8/25/16

Agenda Contractor Performance Rating Systems CPARS PPIRS FAPIIS Final words

Performance Ratings Systems CPARS (www.cpars.gov) PPIRS (www.ppirs.gov) FAPIIS (https://www.fapiis.gov/fapiis/index.action)

Contractor Performance Rating Systems

CPARS FAR Part 42.15 requires that contractor performance information be collected and used in source selection evaluations (FAR Part 15). Source selection officials rely on these evaluations to make informed business decisions when awarding government contracts and orders. The Contractor Performance Assessment Reporting System (CPARS) has been designated as the Federal Government-wide solution for collection of contractor performance information.

CPARS CPARS-generated past performance information is one of the tools used to provide contractor strengths and weaknesses to source selection officials and Contracting Officers. Communication between the Government and contractor during the performance period is essential.

CPARS CPARS collects the information and passes it to the Past Performance Information Retrieval System (PPIRS) Report Card (RC) and the Federal Awardee Performance and Integrity Information System (FAPIIS), the Government-wide performance information repository where it can be retrieved by Federal Government Agencies.

CPARS Required on supply contracts over $5M and service contracts over $1M (see full guidance at Aug 2016 CPARS Guide) Reporting requirements are listed on Table 1 on page 21. Annual reports are completed by an assessing official (for DOD agencies, this person has to be in the program office chain)

CPARS A CPAR includes seven evaluation areas (detailed information on each area is included in Attachment 3 of the CPARS Guide): Technical/Quality of Product or Service Cost Control Schedule/Timeliness

CPARS Evaluation areas (cont’d): Management or Business Relations Small Business Subcontracting Regulatory Compliance Other

CPARS The entire CPARS evaluation process must be completed within 120 days following the end of the period of performance. This timeframe includes the Contractor Representative’s (CR’s) 60 day comment period.

CPARS The CR has a total of 60 days to indicate if they concur or do not concur with the evaluation. If CR comments are sent within the first 14 days and the AO or reviewing official (RO) closes the evaluation, the evaluation will become available in PPIRS-RC within 1 day.

CPARS On day 15 following the AO’s evaluation signature date, the evaluation will become available in PPIRS-RC with or without CR comments and whether or not it has been closed by the AO or RO.

CPARS If no CR comments have been sent and the evaluation has not been closed, it will be marked as “Pending” in PPIRS-RC. If the CR sends comments at any time prior to 61 days following the AO’s evaluation signature date, those comments will be reflected in PPIRS-RC within 1 day. On day 61 following the AO’s evaluation signature date, the CR will be “locked out” of the evaluation and may no longer send comments.

CPARS On day 61 following the AO’s evaluation signature date, the evaluation is returned to the AO and the CR may no longer send comments. If the CR either concurred with the evaluation or did not send comments, the AO may (1) close the evaluation; (2) modify and close the evaluation; (3) send the evaluation to the RO; or (4) modify and send the evaluation to the RO.

CPARS If the AO closes the evaluation or modifies and closes the evaluation, the evaluation will be updated in PPIRS-RC within 1 day and the “Pending” marking will be removed. If the AO sends the evaluation to the RO or modifies the evaluation and sends it to the RO, the evaluation will be updated in PPIRS-RC within 1 day and will retain the “Pending” marking.

CPARS If the CR did not concur with the evaluation, the AO may (1) send the evaluation to the RO for resolution or (2) modify and send the evaluation to the RO

CPARS In both cases, the evaluation will be updated in PPIRS-RC within 1 day and will retain the “Pending” marking. In the event that an evaluation is modified, both the AO’s original ratings and narratives and the AO’s modified ratings and narratives will remain a part of the evaluation record in PPIRS-RC.

CPARS RO comments and signature are required whenever the CR does not concur with the AO’s evaluation and when the AO has sent the evaluation to the RO for closure. The RO should provide comments, sign, and close the evaluation. When the evaluation is closed by the RO, it will be updated in PPIRS-RC within 1 day and the “Pending” marking will be removed.

CPARS The RO also has the option to return the evaluation to the AO for additional changes if desired. In such a case, the AO should make changes as necessary, resend the evaluation to the RO, and the RO should provide comments, sign, and close the evaluation.

CPARS (cont’d) If you disagree with the ratings, you need to challenge them within the allowable time periods CPARS can be changed and even withdrawn A bad CPARS rating will effect your ability to receive future awards

PPIRS

PPIRS In May 2010, PPIRS was designated as the single government wide repository of past performance data. PPIRS consists of two components, Report Card (RC) and Federal Awardee Performance and Integrity Information System (FAPIIS). These three components support the Federal Acquisition Regulation (FAR) requirement to consider past performance information prior to making contract award.

PPIRS (cont’d) Government access is restricted to those individuals who are working on source selections. Contractors may view only their own data.

FAPIIS

FAPIIS Has both a government only accessible site and a public access site. Info flows down from CPARS to PPIRS to FAPIIS

FAPIIS FAR 9.104-6 – Federal Awardee Performance and Integrity Information System. Before awarding a contract in excess of the simplified acquisition threshold, the CO shall review the performance and integrity information available in the Federal Awardee Performance and Integrity Information System (FAPIIS) including FAPIIS information from the System for Award Management (SAM) Exclusions and the Past Performance Information Retrieval System (PPIRS).

Final Words

Final Words As a contractor, your business lives and dies by its performance ratings Respond IMMEDIATELY if you non-concur with your rating If it becomes contentious, request a meeting with the CO and PM (don’t be afraid to go up the chain of command!) Be reasonable – CPARS are subjective and there is nothing wrong with a satisfactory rating

Skyway Acquisition Solutions, LLC        Shelley Hall Email: shelley.hall@skywayacquisition.com www.skywayacq.com