Who Should Read This Report and Why?
Congressional, civilian, and military
personnel responsible for contracting and managing acquisition programs should read
this report to obtain information about contractor past performance information. This
report discusses problems associated with the registration, reporting, quality, and usage
of contractor past performance information.
In the 1994 Federal Acquisition Streamlining Act, Congress
acknowledged that it is appropriate and relevant for the Government to consider a
contractor’s past performance in evaluating whether that contractor should receive future
work. Past performance information is relevant for future source selection purposes,
regarding a contractor’s actions under previously awarded contracts. The Federal
Acquisition Streamlining Act states that past contract performance of an offeror is one of
the relevant factors that a contracting official of an Executive branch agency should
consider in awarding a contract; it is appropriate for a contracting official to consider past
contract performance of an offeror as an indicator of the likelihood that the offeror will
successfully perform a contract to be awarded by that official.
The Contractor Performance Assessment Reporting System was created in 1998 by the
Navy to meet Federal Acquisition Regulation requirements for the collection and
evaluation of contractor past performance information. On December 17, 2004, the
Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics,
Defense Procurement and Acquisition Policy designated the Contractor Performance
Assessment Reporting System as the DoD’s solution for collecting contractor past
performance information. The primary purpose of the Contractor Performance
Assessment Reporting System is to ensure that data on contractor performance are
current, available, and entered into the Past Performance Information Retrieval System
where it can be retrieved by Federal Government agencies, including DoD Departments.
The DoD Contractor Performance Assessment Reporting System did not
contain all active system contracts over $5 million. In addition, for system contracts
that were in the DoD Contractor Performance Assessment Reporting System and
reviewed during the audit, we found that:
- 39 percent were registered more than a year late;
- 68 percent had performance reports that were overdue; and
- 82 percent of past performance assessment reports reviewed did not contain detailed, sufficient narratives to establish that ratings were credible and justifiable.
As a result, Government acquisition officials do not have all past performance
information needed to make informed decisions related to market research, contract
awards, and other acquisition matters (see the finding).
Military Department internal controls were not adequate. We identified material internal
control weaknesses for Military Departments over contractor past performance
information including procedures to initiate registration of contracts in the Contractor
Performance Assessment Reporting System, procedures to prepare performance
assessment reports in a timely manner, procedures to write detailed and qualified
assessments of performance information, and procedures to purge unneeded data.
The Under Secretary of Defense for Acquisition, Technology, and Logistics should
establish the requirement to register contracts in the Contractor Performance Assessment
Reporting System within 30 days from contract award and to complete individual
contract performance assessment reports within 120 days from the end of contract
evaluation periods. He should also require formal training on writing past performance
assessment report narratives and corresponding ratings for the DoD Contractor
Performance Assessment Reporting System assessing officials and the individuals who
review draft past performance assessment reports. The Under Secretary should require
the Military Department major commands to reconcile active contracts with contracts
registered in the Contractor Performance Assessment Reporting System. In addition, the
Under Secretary should require the Military Department major commands to register all
unregistered systems contracts over $5 million and begin preparing required
performance assessment reports, monitor and enforce compliance with the 30-day
registration requirement and 120-day reporting requirement for future systems contracts
over $5 million, and remove excess and outdated information from the Contractor
Performance Assessment Reporting System. (See the Finding section of the report for
the detailed recommendations.)
Management Comments and Audit Response.
We received comments from the
offices of the Under Secretary of Defense for Acquisition, Technology, and Logistics;
and the Assistant Secretary of the Air Force for Acquisition, concurring with our
recommendations. The comments were responsive to the issues we identified in our
report and no additional comments are needed. See the Finding section for a discussion
of the management comments and the Management Comments section for the complete
text of the comments.