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Donna M. Jenkins, Director www.fai.gov National Aeronautics and Space Administration (NASA) Use Of Past Performance Information June 10, 2014 William P. McNally, Assistant Administrator for Procurement Headquarters, NASA
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2 Agenda o NASA Policy on Past Performance o NASA Past Performance Evaluation Source Evaluation Boards (SEB) o Upcoming Past Performance Policy Changes
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NASA Policy Past Performance Not later than 120 days after the end of the period of performance on contracts having a period of performance exceeding one year, NASA Contracting Officers must conduct interim evaluations of performance on contracts subject to FAR Subpart 42.15 o The final evaluation will include an evaluation of the period between the last interim evaluation and the end of the contract period of performance. o Interim performance evaluations are optional for NASA SBIR/STTR Phase II contracts o The Administrator for the Office of Federal Procurement Policy designated DOD’s Contractor Performance Assessment Reports System (CPARS) as the Federal solution for reporting of contractor performance information. CPARS replaced the NASA Acquisition Internet Service (NAIS) Past Performance Database (PPDB) application. 3
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NASA Past Performance Evaluation Source Evaluation Boards (SEB) Past Performance is one of 3 evaluation factors that NASA typically uses: o Mission Suitability – indicates the merit of excellence of the work to be performed. o Cost/Price – evaluates the reasonableness and cost realism of proposed costs. o Past Performance – indicates the relevant quantitative and qualitative aspects of offeror’s record of performing similar efforts. The Past Performance evaluation is an assessment of the Government’s level of confidence in the offeror’s ability to perform the solicitation requirements based upon the offeror’s record of performance. 4
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NASA Past Performance Evaluation Source Evaluation Boards (SEB) NASA requests past performance information from offeror’s (prime and major subcontractors) on relevant project of similar size, scope, and magnitude to the requirements of instant acquisition. The SEB evaluates the offeror’s relevant past performance (e.g. current/recent, size, content, and complexity). Past performance is assessed in areas germane to the instant requirement, such as, technical, cost, schedule, management, occupational health, security, safety, environmental, etc. The past performance information obtained from : o Past Performance databases (e.g. PPIRs) to obtain past performance information of offerors. o NASA includes questionnaires in solicitations for the Offeror’s customers to fill out and return directly to NASA. 5
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NASA Past Performance Evaluation Source Evaluation Boards (SEB) NASA uses “Neutral*”and 5 Level of Confidence Ratings, to include: o very high level of confidence, o high level of confidence, o moderate level of confidence, o low level of confidence, and o very low level of confidence. Neutral is used when an offeror does not have a record of relevant past performance and it is not evaluated or rated favorably or unfavorably. 6
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NASA Past Performance Evaluation Source Evaluation Boards (SEB) The SEB voting members perform an analysis of each offeror’s past performance and summarize the results of the evaluation in a narrative report or as individual findings (i.e., strengths and weaknesses). The SEB meets to discuss the past performance evaluation and then the SEB develops consensus narrative or consensus findings depending on the approach used. The SEB must document a description of the assessment and supporting rationale for all conclusions reached and shall not simply carry forward the information obtained from questionnaires or databases regardless of approach used (i.e., narrative or individual findings). The SEB then reaches consensus on the confidence rating to be assigned consistent with the level of confidence definitions contained in the NASA FAR supplement. 7
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Upcoming Past Performance Policy Changes FAR Case 2012-028 - Contractor Comment Period, Past Performance Evaluations o DoD, GSA, and NASA amended the FAR to implement section 853 of the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2013 and section 806 of the NDAA for FY 2012 that impact past performance evaluations by: providing contractors “up to 14 calendar days…from the date of delivery” “to submit comments, rebuttals, or additional information pertaining to past performance” for inclusion in the database, and requiring that agency evaluations of contractor performance, including any information submitted by contractors, be “included in the relevant past performance database not later than the date that is 14 days after the date of delivery of the information” to the contractor. The FAR currently provides “a minimum of 30 days” for contractor comments, rebutting statements, or additional information. Whether or not a contractor’s additional information/rebuttal has been received, the past performance evaluation will move between systems after 14 days and become available to source selection officials. Final Rule published May 30, 2014 and is Effective July 1, 2014. 8
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Upcoming Past Performance Policy Changes FAR Case 2014-010 - Enhancements to Past Performance Evaluation Systems o DoD, GSA, and NASA are proposing to amend the FAR to accommodate Architect-Engineer Contract Administration Support System (ACASS) and Construction Contractor Appraisal Support System (CCASS) as modules within the Contractor Performance Assessment Reporting System (CPARS) database. This action will standardize the past performance reporting requirements under the CPARS database in FAR Subpart 42.15 9
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BACKUP
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12 The Past Performance Information Retrieval System Report Card (PPIRS-RC) compliance reports are based on a comparison of the contracting action reports (CARs) that are entered into the Federal Procurement Data System Next Generation (FPDS-NG) and completed evaluations in the PPIRS-RC. The metrics represent all fiscal years in PPIRS. The table below provides a breakout by NASA and by individual Center: NASA Past Performance Metrics Office Name Contract Count Contract Completed Count Percentage ARMSTRONG FLIGHT RESEARCH CENTER811619.8% GLENN RESEARCH CENTER20217888.1% NASA HEADQUARTERS29120470.1% MARSHALL SPACE FLIGHT CENTER20115074.6% KENNEDY SPACE CENTER32525177.2% NASA MANAGEMENT OFFICE3266.7% NASA SHARED SERVICES CENTER80360975.8% STENNIS SPACE CENTER685682.4% NMO AT APL11100% AMES RESEARCH CENTER21715772.4% GODDARD SPACE FLIGHT CENTER38326669.5% JOHNSON SPACE CENTER20014472% LANGLEY RESEARCH CENTER22722096.9% NASA Agency3005226475.34%
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