Changes to Contractor Performance Evaluations

Contractor Performance Assessment Reporting System

Ian Mitchell, PE, LEED AP BD+C Chief, Management Support Section & Louisville District A-E Responsibility Coordinator 29 Jan 15

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What Has Changed?

 In the past, CPARS, ACASS and CCASS contained differing contractor evaluation forms, rating elements, and workflow processes.  The CPARS, ACASS and CCASS modules have been merged into a single application developed by the Naval Sea Logistics Center Portsmouth under the CPARS name.  The merge includes the transition to common evaluation entry fields with a common set of rating elements in addition to a transition to a common workflow process.

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Why do we evaluate performance?

Regulatory Requirements FAR 42.1502

 Past Performance Evaluations Prepared: ► At Least Annually ► At Time Work Under Contract or Order is Completed ► Past Performance Information Shall be Entered Into CPARS

FAR 42.1503

 Evaluation Factors (Technical, Cost Control, Schedule, Management, Small Business Subcontracting, other)

FAR 15.304



Past Performance Shall be Evaluated in all Source Selections for Negotiated Competitive Acquisitions

Expected to Exceed Simplified Acquisition Threshold 3

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Why Change to CPARS?

 Implements one of the Government Accountability Office (GAO) recommendations in audit GAO-09 374 “Federal Contractors: Better Performance Information Needed to Support Agency Contract Award Decisions” dated April 23, 2009. 

Issues discovered:

► skepticism about the reliability of the information ► a lack of central oversight and management 

GAO recommendation: standardize evaluation factors and rating scales government-wide.

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The End Result

 A single streamlined and optimized system  Merging of CPARS and the Past Performance Information Retrieval System (PPIRS) into the Integrated Award Environment 5

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When will CPARS use begin?

 Louisville District began entering CPARS evaluations for A-E Contracts into the system starting in mid January 2015 and construction began in late 2014.

 The CPARS process for both construction and engineering is a work in progress.

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Changes

 The DD2631 (ACASS) and the DD2626 (CCASS) are no longer being used.  The PDF version of the evaluation is no longer being used.

 The interface to the Resident Management System (RMS) for construction and A-E performance has been removed.  Data elements have been revised; fields for Project Title and Complexity have been added.

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Changes – Cont.

     The terms “Rating Official” and “Evaluating Official” have been changed to “Reviewing Official.” The Reviewing Official will be optional for Architect-Engineer and Construction evaluations. A Reviewing Official will only be required in the event that the Contractor Representative does not concur with the evaluation.

Completed Architect & Engineering and Construction evaluations will no longer overwrite previously completed evaluations. All evaluations, including Architect-Engineer and Construction, will be archived from CPARS three years following contract completion . Retentions in PPIRS will remain the same at six years from the contract completion date.

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What will be evaluated

 All Architect-Engineer (A-E) contracts that are over $30,000 or terminated for default will receive a

final

performance evaluation.  All A-E contracts that are over $30,000 with a period of performance over one year will receive

interim

performance evaluations annually.

 All A-E contracts that include preparation of construction documents and are over $30,000 will receive an

addendum

performance evaluation at the conclusion of construction.

► This includes contracts with and without construction phase services

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Elements of CPARS Evaluation

   

Rating Elements

► Quality ► Schedule ► Cost Control ► Management ► Utilization of Small Business ► Regulatory Compliance ► Other Evaluation Areas (three total)

Comments will be made on each area An overall rating will be given in the “Other” Section Individual disciplines will be evaluated in the comments section for “Other”

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LRL CPARS Entry Form

  Helps with consistency between numerous Government Project Engineers Based on guidance included in ECB 2014-13* * http://www.hnc.usace.army.mil/Missions/Engineering/TECHINFO.aspx

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Input into CPARS

       

Typical Project and Company Information Evaluation Type: Interim, Final or Addendum Total Dollar Value Current Contract Dollar Value Location of Work Complexity: High, Medium or Low Contract Effort Description Key Subcontractors and Effort Performed BUILDING STRONG ®

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Quality

 Contractor’s management of the quality control program and Quality of the work itself ► Did the AE follow their Quality Management Plan?

► Did the AE perform appropriate site investigations?

► Were deliverables accurate and coordinated?

► Were the deliverables clear and sufficiently detailed?

► Did the AEs provide a functional and useable product?

► Did the AE provide an aesthetically designed facility?

► ► Did the AE provide appropriate and timely responses?

Was the design prepared in accordance with the present sustainability and environmental requirements?

► Did the AE develop and implement any innovative approaches?

► Was the product biddable with a minimum number of amendments?

► Were all design products submitted in the appropriate format?

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Schedule

 Assess the timeliness of the Contractor against the required completion date of the contract, milestones, delivery schedules, and administrative requirements ► Did the AE adhere to the schedule within their contract/task order?

► Were all deliverables submitted as required per the schedule?

► If the AE was not able to adhere to their schedule, did they develop a corrective action plan and follow this plan?

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Cost Control

 Typically used to evaluate Cost Contracts. For AE contracts, the purpose of this element will be to evaluate the AE’s

cost estimating

performance. If there was no cost estimating in the AE’s scope, then this area shall be N/A. Factors to consider: ► If a design, was the cost within the cost limitations specified in the contract/task order?

► ► For other products such as studies, was meaningful cost data provided to support the results of the product?

Were the submitted estimates performed with sufficient detail and accuracy?

► If a Value Engineering study was performed, was AE cooperative in implementing approved recommendations?

►

FAR 36.609-1 Design within funding limitations.

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Management of Key Personnel

 Should reflect the Contractor’s internal and external day to-day business operations as they relate to meeting contract requirements. Factors to consider: ► Did the AE’s project manager provide the appropriate leadership?

► Did the AE exhibit reasonable and cooperative behavior?

► Did the AE manage their consultants?

► Did the key personnel identified to participate remain involved?

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Utilization of Small Business

 This category may be rated N/A for small business contracts. This area must be rated for all contracts and task orders that contain a small business subcontracting plan. Assess compliance with all terms and conditions in the contract relating to Small Business participation.

► Compliance with Federal Acquisition Regulation (FAR) 52.219-8, Utilization of Small Business ► ► Compliance with FAR 52.219-9, Small Business Subcontracting Plan Contractor’s good faith effort(s) to meet contract goals and requirements ►

eSRS

(Electronic Subcontracting Reporting System)

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Regulatory Compliance

 Architect-Engineer evaluations shall be N/A unless a specific component of design or engineering services is governed by an environmental regulation is important enough to be broken out from the quality rating.

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    Overall Rating Discipline Specific Ratings Will be in comments section of CPARS under “Other”

Not Per the ECB for A-E Contracts

Other

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Recommendation



Given what I know today about the contractor's ability to perform in accordance with this contract or order’s most significant requirements, I Recommend or I Do Not Recommend them for similar requirements in the future

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Concerns with CPARS

    No overall rating Built-in Cost growth is not easily attained ► Total Dollar Value Includes Un-awarded Options ► Current Dollar Value Includes awarded options and mods Several fields do not align with the areas important to the district No requirement for A-E responsibility data ► Construction Cost Growth ► Damages to the Government

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CPARS Roles

Focal Point/Alternate Focal Point (FP/AFP): Registers Contracts, Assigns Users, Provides Support Assessing Official Rep (AOR): Assists Assessing Official in Preparing Evaluation Assessing Official (AO): Sends Evaluation to Contractor Rep; Reviews Contractor Comments https://www.cpars.gov

22 Contractor Rep (CR): Provides Comments Reviewing Official (RO): Resolves Disputes

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CPARS Timeline

Within 30 Days of Contract Award FP/AFP, AOR, or AO Registers Basic Contract Information 2 335 Days After Contract Award 3 4

https://www.cpars.gov

365 - 485 Days After Contract Award 365 – 485 Days After Contract Award

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Evaluation Appears on AOR/AO To Do List AOR/AO Enters Evaluation Ratings & Narratives AO Sends Evaluation to CR BUILDING STRONG ®

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CPARS Timeline

Days 1 – 14 After Eval Sent to CR CR May Send Comments If CR Sends Comments and AO/RO Closes, Eval Sent to PPIRS 6

https://www.cpars.gov

Day 15 After Eval Sent to CR

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Eval Available in PPIRS: - With or Without CR Comments - Whether or Not It Has Been Closed by AO/RO

Note: Eval Marked as “Pending” if Not Closed

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https://www.cpars.gov

CPARS Timeline

Days 15 – 60 After Eval Sent to CR CR May Send Comments if None Previously Provided Day 61 After Eval Sent to CR If CR Sends Comments, PPIRS Updated to Reflect CR Comments; “Pending” Marking Removed When AO/RO Closes Eval Eval Returned to AO; CR Locked Out of Eval & May No Longer Send Comments

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CPARS Timeline

Day 61 After Eval Sent to CR – Day 120 After End of Period of Performance

https://www.cpars.gov

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AO Must Either: - Close Eval (Eval Updated in PPIRS) - Modify & Close Eval (Eval Updated in PPIRS) - Send Eval to RO (Eval Updated in PPIRS as “Pending”) - Modify & Send Eval to RO (Eval Updated in PPIRS as “Pending”)

Note: “Pending” Marking Removed When Eval Closed

AO Must Either: - Send Eval to RO (Eval Updated in PPIRS as “Pending”) - Modify & Send Eval to RO (Eval Updated in PPIRS as “Pending”) BUILDING STRONG ®

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CPARS Timeline

Prior to Day 121 After End of Period of Performance RO Provides Comments & Closes Eval; Eval Updated in PPIRS with “Pending” Marking Removed

The entire CPARS evaluation process must be completed within 120 days of the end of the period of performance!

https://www.cpars.gov

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For More Information www. cpars.gov

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Questions?

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