1. SMALL BUSINESS SUBCONTRACTING Presented to: Southern Maryland Chapter of PMI Presented by: Emily Harman Associate Director NAVAIR Office of Small Business Programs 25 March 2014 Presented to: Southern Maryland Chapter of PMI Presented by: Emily Harman Associate Director NAVAIR Office of Small Business Programs 25 March 2014 NAVAIR Public Release 08-005 Distribution Statement A – “Approved for public release; distribution is unlimited”

2. Agenda Small Business (SB) Contracting Goals Regulatory Requirements and Policy Subcontracting Plan Types SB Subcontracting Considerations in Source Selections SB Utilization Strategy vs. SB Subcontracting Plan Competitive SB Subcontracting Plan Review Process Individual Subcontracting Plans Electronic Subcontracting Reporting System Contractor Performance Assessment Rating System Recent Legislative and Regulatory Changes File: NAVAIR SB Source Selection 2

3. Small Business Contracting Goals Federal Prime Contracting Goals –23% of all Federal Procurements will be awarded to SB including socio-economic entities 5% Small Disadvantaged Business (SDB) 5% Women-Owned SB (WOSB) 3% Historically Underutilized Business Zone (HUBZone) SB 3% Service-Disabled Veteran-Owned SB (SDVOSB) DoD Goals negotiated with Small Business Administration –FY14 21.35% prime contracting –FY14 36.7% subcontracting 5% Small Disadvantaged Business (SDB) 5% Women-Owned SB (WOSB) 3% Historically Underutilized Business Zone (HUBZone) SB 3% Service-Disabled Veteran-Owned SB (SDVOSB) 3

4. FOR OFFICIAL USE ONLY Authority: Section 8(d) Small Business Act – 15 USC 637(d) Specifies that small businesses will have maximum practicable opportunity to participate in contract performance consistent with efficient performance Section 15(g) Small Business Act – 15 USC 644(g) Specifies government-wide goals for contracts and subcontracts awarded to small business concerns Regulations: FAR 19.7 / DFARS 219.7, Small Business Subcontracting Program Small businesses will have maximum practicable opportunity to participate in contract performance consistent with efficient performance FAR 52.219-8, Utilization of Small Business Concerns Subcontracting Plan requirement FAR 52.219-9 / DFARS 252.219-7003 SB Subcontracting Plan (Two DEVIATION) Comply in good faith with subcontract plan requirements FAR 52.219-16, Liquidated Damages Imposition of liquidated damages DFARS 252.219-7004, SB Subcontracting Plan (Test ) (DEVIATIO N)  Regulatory Requirements 4

5. Subcontracting Policy When Required Contracts > $650K ($1.5M construction) AND subcontract opportunities exist Modifications > $650K ($1.5M construction) with new work AND subcontract opportunities –Revise existing plan if there is one Modifications that push the total contract value > $650K Multi-year contracts/contracts with options –Cumulative value of base contract & all options –SEPARATE goals for base and each option When Not Required From small businesses For personal service contracts For contracts / modifications performed entirely outside US & outlying areas For modifications to contracts within general scope of the contract that do not contain FAR 52.219-8 (or equivalent prior clauses, e.g., contracts awarded before enactment of PL 95-507) If no subcontract opportunities exist – approval required at one level above the Contracting Officer "Negotiated acquisitions…shall require the successful offeror to submit an acceptable subcontracting plan…" References FAR 19.7 DFARS 219.7 DOD Subcontracting Plan Fact Sheet on the DOD OSBP ‘s web site: http://www.acq.osd.mil/osbp DOD Subcontracting Plan Fact Sheet on the DOD OSBP ‘s web site: http://www.acq.osd.mil/osbp 5

6. Subcontracting Plan Types Individual – 1 contract 1 Plan Entire contract period of performance including options Contains 11 mandatory elements Reports: Semi-annual ISR/Annual SSR Master – All elements except goals & related items Individual goals negotiated for EACH contract; submitted w/ Master Plan Three year period / contract duration DCMA approves May be for plant/division Semi-annual ISR & SSR Commercial – Preferred for commercial items Contains 11 mandatory elements Updated annually, Contractor’s FY May be for plant/division Annual SSR (Govt & Commercial sales) Comprehensive – DoD test program (DFARS 19.702) through 31 Dec 2014 11 participants with plans in effect at corporate, sector or division level Updated annually, Government FY May be for plant/division/corporation DCMA negotiates and administers Semi-annual SSR (All DoD sales), may include program level reporting All plans must include required elements (FAR 19.704(a)) 6

7. Small Business Utilization Strategy in Source Selections On 4 Mar 2011, OSD Defense Procurement Acquisition Policy (DPAP) issued revised Source Selection Procedures, effective 1 Jul 2011 –http://www.acq.osd.mil/dpap/policy/policyvault/USA007183-10- DPAP.pdfhttp://www.acq.osd.mil/dpap/policy/policyvault/USA007183-10- DPAP.pdf SB Utilization Strategy must be evaluated in all full & open competitions where required by FAR 15.304(c), FAR 19.1202, and DFARS 215.304(c)(i) USD(AT&L) Better Buying Power memo, 14 Sep 10 Emphasis on SB utilization through weighting factors in past performance and fee construct, on all competitive and non-competitive procurements Initiatives to engage Large Business (LB) primes to increase subcontracting with quality SBs How do they intend to include SB and how does this inclusion add value, promote competition, reduce costs and increase innovation? Goal to expand industrial base: promote competition and reduce program costs File: NAVAIR SB Source Selection 7

8. Small Business Considerations in Source Selections File: NAVAIR SB Source Selection SB Utilization Strategy SB Subcontracting Plan SB Utilization Past Performance* Evaluate Three Areas during Source Selections All three areas must consider past performance on prior subcontracting plans and contracts and rely upon current market research Data Provided as Part of the Proposal Submitted With Proposal; Will be Incorporated into the Contract * Note: The SB Utilization Past Performance evaluation is performed as an integral part of the source selection Past Performance evaluation. 8

9. SB Utilization Strategy vs. SB Subcontracting Plan The RFP and the FAR have different requirements. Notional RFP Section L (SB Utilization Strategy) FAR 52.219-9(d)(…) (SB Subcontracting Plan) File: NAVAIR SB Source Selection 9

10. Competitive SB Subcontracting Plan Review File: NAVAIR SB Source Selection Source Selection Evaluation Subcontracting Plan Review Proposals Received SB Utilization Strategy Evaluated SB Past Performance Evaluated SB Subcontracting Plan Checked for compliance with FAR/DFARS Yields: Evaluation Worksheet Yields: Positive/Negative/Neutral Findings Yields: Yes or No Apparently Successful Offeror's Plan Competitive Range Offerors' Plans All Offerors' Plans SB Subcontracting Plan(s) Routed VIA: CCI 4200.42B Process & Checklist PCO/One Level Above PCO Approves Incorporate Plan at Contract Award DCMA, Specialist, OSBP, SBA PCR Reviews & Provide Recommendations OR Yields a Specific Recommendation: Plan is acceptable to incorporate, OR Recommend negotiating further, OR Reject and return to contractor for re- submittal (PCO decides which) Hint: The review takes time; 10 working days for OSBP/SBA. 10

11. Sample Section M The Offeror’s strategy for utilizing Small Business, Small Disadvantaged Business, Women-Owned Small Business, HUBZone Small Businesses, Veteran-Owned Small Business, and Service-Disabled Veteran-Owned Small Business concerns as well as its consistency with the proposed Small Business Subcontracting Plan (if applicable) will be evaluated. Such evaluations will focus on the extent of participation by small business concerns and the methods and effectiveness of the Offeror in finding, encouraging, and commitment to the use of these small business concerns in its business approach. The Offeror’s demonstrated realism will also be assessed. If this is a set-aside competition, the contractor’s compliance to FAR Clauses 52.219-14 “Limitation on Subcontracting,” 52.219-27 “Notice of Total Service-Disabled Veteran-Owned Business Set Aside,” or 52.219-3 “Notice of Total HUBZone Set Aside,” as applicable, will be evaluated. An Offeror’s proposal that fails to meet the limitation on subcontracting during each period of performance shall not be considered for award. File: NAVAIR SB Source Selection 11

12. Individual Subcontracting Plans Mandatory Plan Elements: FAR 19.704(a) Subcontracting Plan Requirements DFARS 219-704 Subcontracting Plan Requirements Clauses: FAR 52.219-9 DEVIATION Small Business Subcontracting Plan Class Deviations 2008-O0008 & 2009-O0006 mandate hardcopy reporting for BAAs and BPA orders DFARS 252.219-7003 Small Business Subcontracting Plan (DoD Contracts) DFARS 252.219-7004 only used with contractors who have approved (FY basis) Comprehensive Subcontracting Plans Guidance on what we look for when reviewing Plans (FAR 19.705-4) Remember to submit the Plan with your proposal It can take several weeks to review (including DCMA), must be acceptable to the PCO and must be incorporated into the contract 12

13. One Contract – One Plan FAR 19.705-2(e) Contracts Plan must include entire anticipated scope Must have separate sections for the base period and each option, summed up to a total for the contract Contract modifications which increase scope require Individual Subcontracting Plan (ISP) modifications Recommend showing current goals, new proposed goals for the modification, and new ISP total For Example: Large 650000065.0%15000066.7%665000065.0% Small350000035.0%7500033.3%357500035.0% Total1000000022500010225000 SB 5000005.0%10000044.4%6000005.9% VOSB 5000005.0%5000022.2%5500005.4% SDVOSB 3000003.0%5000022.2%3500003.4% SDB 4000004.0%2500011.1%4250004.2% HUBZone 3000003.0%2500011.1%3250003.2% WOSB 500000.5%00.0%500000.5% TOTAL PLANCURRENT PLANECP XYZ 13

14. One Contract – One Plan (continued) Basic Ordering Agreements (BOAs) Each order is a contract which requires a separate ISP (unless covered by a Comprehensive Subcontracting Plan) Ensure order number (i.e. N00019-10-G-0001-0033) is on the title page of the ISP to uniquely identify the scope of the Plan Listing goals for each order in an appendix doesn’t constitute a stand-alone ISP; feasibility of a Master Subcontracting Plan? 14

15. Goals (52.219-9(d)(1) and (2)) Check the math! Many times the percentages aren’t calculated properly Ensure the spreadsheet has correct equations Targets are calculated as a percentage of total subcontracted value Acknowledge the DoD Subcontracting goals Provide rationale to support proposed goals Why opportunities are limited Why additional in-house work can’t be broken out for new SB suppliers Why alternative SB suppliers can’t be developed Provide summary/comparison with prior contracts’ SB goals vs actuals for similar work Identify steps you’re taking to remove barriers to SB subcontracting Explain it to someone who is NOT familiar with what you’re providing/manufacturing DCMA, Small Business Administration PCR, NAVAIR OSBP Be SPECIFIC – specific to the contract and its deliverables Boilerplate language is NOT desirable in ISPs What are the characteristics that make scope elements unsuitable for SBs? 15

16. Goal Justification Inadequate Rationale Examples: “Using only established suppliers” “Unable to find SBs” "We haven't identified the suppliers yet" Better Rationale Encompasses: Schedule impacts that couldn’t have been mitigated by planning for follow-on contracts Data rights Unique technologies Low SB participation in the NAICS codes being subcontracted for and the market research to support this claim Competition results Long term agreements Small businesses that have grown large Certifications required from suppliers, what the certifications are and how specialized they are Government requirements in the contract (we will verify the assertion) 16

17. Goal Justification (continued) Put your explanations & justifications in the Plan Often a cover letter or a response to questions from NAVAIR Contracts yields a clear explanation to support goals. This needs to go into the Plan from the outset A zero indicates no goal being established in that category No attempt will be made to find a SB in that category This is especially problematic – rationale must be very strong to show absolutely no opportunities exist for that category of SB within the entire scope of the contract Goals need to be realistic and attainable, but still provide maximum opportunity; zero is the absence of an opportunity Goals must be consistent with cost & pricing data Low goals (less than DoD goals) can be acceptable – provided the supporting rationale is included 17

18. Poor Goal Justification Examples “[we have] not subcontracted with diverse suppliers for this effort because the developmental requirements for this effort have unique sourcing requirements and are limited to OEM large business suppliers.” What are the “unique sourcing requirements”? Why are the requirements “limited to OEM”? “[this is an] opportunity to add revised work content to our existing supply base being utilized on the [XYZ] Program.” Why no efforts to identify SB suppliers? What is it about the work content that prevents alternate suppliers? Would there be potential suppliers for the future if pursued now? 18

19. Poor Goal Justification Examples (continued) “…this is non-recurring development of a new system; thus, precludes using small businesses” Initial developments of new systems often lay groundwork for future supply base; why can’t opportunities for SBs be aggressively pursued in this phase? Are there plans to offload efforts in later phases (via drawing packages, etc) “…based on the nature of the SOW” What is it about the nature of the SOW that makes it unsuitable? “…life-of-type buy from OEM to resolve parts obsolescence issues” There are many, many suppliers of “obsolete parts” – why can’t they be procured from a second source? 19

20. A Better Example (Yes, it’s Real!) This effort only involves performing the Non-Recurring Engineering for the XYZ which will result in delivery of an ECP to the Government that will be used for the next contractual phase, the forward fit and retrofit of the aircraft. The government directed us to pursue a non-developmental item (NDI) approach for the XYZ. The follow on contract will involve incorporating a NDI, which may very well result in selecting a small business to provide the XYZ. Due to the NRE nature of this modification, no other subcontract opportunities exist for labor support. However this contract modification does involve $100,000 of material. Only a small portion of the material dollars has small business involvement. The majority of the material costs for this effort involve characterization testing which involves conducting the critical environmental and electromagnetic testing of the XYZ. We have selected the same testing facility to perform these tests as we have on previous modifications in the past. The continuity of using the same testing facilities and procedures is very important to the successful selection of the XYZ vendor for the next contractual phase. The testing alone represents over 90% of the total material dollars. Another 9% of the total material dollars consists of XYZ instrumentation and some of the hardware that is needed from the existing version of the XYZ in order to conduct comparative testing. Therefore, no other subcontract opportunities exist for small business at the subcontract level. Less isn’t more – let us know what you’re really doing 20

21. Principal Supplies & Services (52.219-9(d)(3)) List ALL subcontracted supplies/services Include large businesses as well as small businesses Strongly recommend providing the applicable NAICS code(s) This gives us an opportunity to see what kinds of work scope, supplies & services are being reserved for large busine sses 21

22. Efforts To Find Small Businesses (52.219-9(d)(5)) Document: Conferences Websites (more than System of Award Management, SAM!!!) VetBiz Vendor Information Pages, NAVAIR OSBP website “Find an Industry Partner”, other companies’ Small Business Liaison Officers, SBA Dynamic Small Business Search, SBA SUB-Net (Primes post solicitations or notices of sources sought for small business), etc. Include Small Business Innovation Research (SBIR) & Small Business Technology Transfer (STTR) efforts Include Mentor-Protégé Program efforts Identify targeted/specific/focused efforts to raise SB participation in socio-economic categories where it’s lower than desired Note also that websites and sources of information change over time: If you use one Plan as a starting point for another Plan, ensure sources are up-to-date For example: SAM, not CCR 22

23. Cooperation (52.219-9(d)(10)) Flow down of Subcontracting Plan clauses to large businesses that receive subcontracts over $650K Reporting via eSRS (not SF294s and SF295s – unless BOA orders) Ensure your subcontractors with subcontracting plans agree to submit reports in eSRS Require each subcontractor with a subcontracting plan provide the: Prime contract number; It’s own DUNS number; and Email address of the subcontractor’s official responsible for acknowledging receipt or rejecting the ISRs, to its subcontractors with subcontracting plans Visit the DoD OSBP’s web site for information on how to submit reports http://www.acq.osd.mil/osbp/sbs/esrs.shtml 23

24. Things Being Done Well Method used to develop goals (52.219-9(d)(4)) Inclusion/exclusion of indirect costs (52.219-9(d)(6)) is almost always noted, however… If indirect costs are included, ISP needs to identify method whereby indirect costs are allocated among SB socio-economic categories Identification / duties of SB administrator (52.219-9(d)(7)) Efforts to ensure SBs have an equitable opportunity to compete (52.219-9(d)(8)) If applicable, list set-aside competitive efforts, special terms & conditions to put SBs on an even playing field, 52.219-9(e)(1), etc. Recordkeeping (52.219-9(d)(11)) 24

25. Electronic Subcontracting Reporting System (eSRS) 25

26. Electronic Subcontracting Reporting System (eSRS) Background – FAR modified Apr 08 to replace hardcopy Subcontracting reports (SF294 and SF295) with electronic submission at www.esrs.govwww.esrs.gov –DoD directed implementation as of Oct 08 Prime and major subcontractors will report progress on small business subcontracting goals semi-annually –30 April and 30 October –Year-end SBD report no longer required (CD #2013-O0014) eSRS accuracy relies upon FPDS-NG and SAM accuracy –Contractor data is pulled from SAM –Contract data is pulled from FPDS-NG; Contracting Officer must ensure the Contract Action Report (CAR) is filled out correctly CAR field "Subcontract Plan" - choose either: -"Plan Required - Incentive Included" OR -"Plan Required - Incentive Not Included" Otherwise contractors will not be able to submit reports 26

27. Responsibilities Under eSRS Primes & higher-tier subcontractors review their subs’ ISRs Government reviews the prime’s ISR and all SSRs The Contract Specialists/PCOs: –Ensure Apr 08 clause 52.219-9 is used / updated where applicable on contracts –If BOA or BPA, ensure DEVIATED clauses 52.219-9, 252.219-7003 and 252.219-7004 are used (CD #2008-O0008 and CD #2009-O0006) –Requires hardcopy SF294 reporting for each order (BOAs & BPAs ONLY) –eSRS cannot handle multiple ISRs with the same contract number –Advise prime contractor to email notifications to PCO and ACO when they submit their reports –Within 30 days of submission, ACKNOWLEDGE or REJECT ISRs ACKNOWLEDGE using “Accept” –is not considered acceptance of reported information REJECT if incorrect (i.e. wrong contract number) or incomplete Also, contractor may request rejection in order to make a change Incomplete reports should be rejected. Failure to meet goals is not a reason for rejection! Incomplete reports should be rejected. Failure to meet goals is not a reason for rejection! 27

28. Contractor Performance Assessment Rating System (CPARS) and Small Business FEB 09 CPARS update included new rating element for Utilization of Small Business –Provides more focus & visibility into SB performance, and holds the contractors more accountable for their best efforts –Required for CPARS, including Systems, Services and IT… –Whenever SB subcontracting goals are part of the contract/BOA order/BPA –Not required for single-agency task orders or delivery orders Previously, SB Utilization was part of the Subcontract Management rating New element rates the following: –Contractor’s compliance with SB Subcontracting Plan program –Whether contractor provides “maximum practicable opportunity” to SBs –Contractor’s efforts to achieve goals in their Subcontracting Plan OSD(AT&L) established new criteria for SB Utilization CPARS colors 28

29. SB CPARS Rating Definitions See the CPARS Policy Guide (Sep 2013) for detailed SB definitions and ratings http://www.cpars.gov/cparsfiles/pdfs/CPARS-Guidance.pdf +/- may be used to indicate trends (+ or -) insufficient to change evaluation status (color) RatingSubcontracting PlanReportsBenefits/Impacts Dark Blue - Exceptional Exceeded all goals or exceeded at least one and met all others Accurate & timely Multiple significant events of benefit Purple - Very Good Met all traditional goals and at least one other goalAccurate & timely Significant event of benefit Green - Satisfactory Good faith effort to meet goalsAccurate & timely Minor problems or major problems w/ corrective action Yellow - Marginal Deficient in meeting key Plan elements Inaccurate or untimely Significant event contractor had trouble overcoming Red - Unsatisfactory Noncompliant; uncooperative Inaccurate or untimely Multiple significant problems; liquidated damages 29

30. Recent Legislative and Regulatory Changes ***DoD will implement these changes once they are incorporated into the FAR. This is a heads up on future subcontracting policy.*** 30

31. SBA Final Rule – Implementing Provisions of the 2010 Jobs Act Small Business Subcontracting For contracts requiring a small business subcontracting plan, the prime contractor must notify the contracting officer in writing whenever the prime contractor does not utilize a small business subcontractor used in preparing its proposal during contract performance. Requires a prime contractor to notify a contracting officer in writing whenever the prime contractor reduces payments to a small business subcontractor or when payments to a small business subcontractor are 90 days or more past due. Clarifies that the contracting officer (CO) is responsible for monitoring and evaluating small business subcontracting plan performance. Clarifies which subcontracts must be included in subcontracting data reporting, which subcontracts should be excluded, and the way subcontracting data is reported. CO must record identity of prime contractor with history of unjustified, untimely payments to subcontractors in Federal Awardee Performance and Integrity Information System (FAPIIS). Prime contractor may not prohibit a subcontractor from discussing any material matter pertaining to payment or utilization with the CO. Final Rule issued 16 July 2013 –(78 Fed. Reg. 42391) 31

32. SBA Final Rule – Implementing Provisions of the 2010 Jobs Act Multiple Award Contract Set-Asides Limitations on Subcontracting/Nonmanufacturer Rule –Compliance with Limitations on Subcontracting and nonmanufacturer rule measurements Total and partial set-aside MACS -Measured under each performance period of the contract (base and then each option year) -Contracting Officer has discretion to require measurement based on period of performance for each task order Full and open or reserved set-aside MACs -Measured over the period of performance of the task/delivery order Final Rule issued 2 October 2013 –(78 Fed. Reg. 61114) 32

33. FOR OFFICIAL USE ONLY FY13 National Defense Authorization Act PART IV—TRANSPARENCY IN SUBCONTRACTING SUBPART A—LIMITATIONS ON SUBCONTRACTING Sec. 1651: Limitations on subcontracting Changes calculation for the limitations on subcontracting to “more than 50% of the amount paid” to the prime contractor No longer cost based Utilization of similarly situated entities allowed Sec. 1652: Penalties Penalty the greater of $500,000 or dollar amount expended in excess of permitted levels on subcontractors SUBPART B—SUBCONTRACTING PLANS Sec. 1655: Subcontracting plans Timelines for submitting subcontracting reports SBA must modify subcontracting reporting system to notify the Contracting Officer and Office of SB Programs if an entity fails to submit a required report Failure to submit subcontracting reports is a breach of contract 33

34. FOR OFFICIAL USE ONLY FY14 National Defense Authorization Act Sec. 1614: Credit for certain small business subcontractors Amends the SB Act to require the offeror and all subcontractors required to maintain subcontracting plans to: Review and approve subcontracting plans submitted by their subcontractors Monitor subcontractor compliance w/ subcontracting plans Ensure subcontracting reports are submitted by subcontractors when required Acknowledge receipt of their subcontractors’ reports Compare performance of subcontractors to subcontracting plans and goals Discuss performance with subcontractors when necessary to ensure subcontractors make good faith effort to comply with their subcontracting plans 34

35. FOR OFFICIAL USE ONLY FY14 National Defense Authorization Act Highlights Sec. 1614: Credit for certain small business subcontractors (continued) Addresses how credit for certain subcontractors will be determined Subcontracting goals pertain to a single contract with an executive agency – prime receives credit for SB subcontractors at any tier Subcontracting goals pertain to more than one contract with one or more executive agencies or to one contract with more than one executive agency – prime receives credit for first tier subcontractors only Prime contractor is responsible to make a good faith effort to achieve first tier subcontracting goals 35

36. Questions?

37. Backup

38. CPARS Evaluation Rating Definition – Exceptional Source: CPARS Policy Guide http://www.cpars.gov/cparsfiles/pdfs/CPARS-Guidance.pdf Source: CPARS Policy Guide 38

39. CPARS Evaluation Rating Definition – Very Good Source: CPARS Policy Guide http://www.cpars.gov/cparsfiles/pdfs/CPARS-Guidance.pdf Source: CPARS Policy Guide 39

40. CPARS Evaluation Rating Definition - Satisfactory Source: CPARS Policy Guide http://www.cpars.gov/cparsfiles/pdfs/CPARS-Guidance.pdf Green/ Satisfactory Demonstrated a good faith effort to meet all of the negotiated subcontracting goals in the various socio- economic categories for the current period. Complied with FAR 52.219-8, Utilization of Small Business Concerns. Met any other small business participation requirements included in the contract/order. Fulfilled the requirements of the subcontracting plan included in the contract/order. Completed and submitted Individual Subcontract Reports and/or Summary Subcontract Reports in an accurate and timely manner. To justify a Satisfactory rating, there should have been only minor problems, or major problems the contractor has addressed or taken corrective action. There should have been no significant weaknesses identified. A fundamental principle of assigning ratings is that contractors will not be assessed a rating lower than Satisfactory solely for not performing beyond the requirements of the contract/order. 40

41. CPARS Evaluation Rating Definition - Marginal Source: CPARS Policy Guide http://www.cpars.gov/cparsfiles/pdfs/CPARS-Guidance.pdf 41

42. CPARS Evaluation Rating Definition - Unsatisfactory Source: CPARS Policy Guide http://www.cpars.gov/cparsfiles/pdfs/CPARS-Guidance.pdf 42