Report | Feb. 29, 2008

Contractor Past Performance Information

D-2008-057

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.

Background.

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.

Results.

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.