In February 1997, ASN(RD&A) chartered the Department of the Navy (DoN) past performance IPT. The team was tasked to establish methods for collecting data on contractor past performance. Shortly after the establishment of the DoN IPT, USD(A&T) established a DoD OIPT to accomplish the same task on a DoD-wide basis. Members of the DoN IPT participated in the DoD OIPT, with the rest of the DoN IPT supporting their efforts.
The DoD OIPT, after consultation with industry, rejected the idea of a "one size fits all" approach to the collection of past performance information, instead, adopting a business sector approach. The DoD OIPT identified business sectors and established working IPTs (WIPTs) for those business sectors. The WIPTs included representatives of the activities that do business in each sector. The WIPTs, with industry participation through CODSIA and other associations, recommended the elements of past performance information (PPI) to be collected, the approach for maintaining PPI, thresholds for collection of PPI, and the method for contractor review and comment. The DoD OIPT further refined the recommendations, developed an implementation schedule, and developed a five level assessment rating system to enhance the ability to share PPI throughout DoD.
A DoN CPARS Guide was initially issued on 2 Feb 98. The DoN IPT has transitioned to a Policy/Configuration Management Board (CMB) that has now updated the CPARS Guide to reflect DoN policy changes as well as ensure consistency with the DoD Guide to Collection and Use of Past Performance Information (May '99).
1. Should PPI be collected for joint ventures?
Yes, PPI should be collected for 'joint venture' contractors when the applicable business sector and dollar thresholds indicate that the contract is PPI eligible. There is no indication from current guidance that joint ventures should be excluded. Also, remember that the intent of the data collection is not only for future DoN source selections, but also to share with other agencies. Your PPI input may be very valuable to other agencies, even if you think that DoN might not procure an item involving this particular joint venture in the future.
2. Are CPARs required for delivery orders (DOs)?
Yes. The information contained in a performance assessment of work performed under a DO is equally as important as that performed under a stand-alone contract, or any other type of procurement instrument.
3. Who should prepare the CPARS for DOs?
The CPARS Guide, paragraph 2.7, states: "For delivery order or task order contracts, the contracting officer should specify in the contract the frequency of, and the individual(s) responsible for, past performance assessments associated with orders to be placed against that contract." In general, it makes the most sense for the person or persons with the most knowledge (i.e., closest to the process) to prepare the CPARS.
4. Can a single CPARS be prepared for multiple work efforts?
Yes, when it makes sense in context of reviewing the data in a future source selection. See CPARS Guide, paragraph 2.2: "When a single contract instrument requires segregation of costs for combining efforts, or contains multiple production lots (or increments of work), an individual CPAR may be completed for each segment of work. When the type of effort and the contractor's performance on each order are so similar as to reflect identical results, the program manager in consultation with the CPAR focal point may elect to prepare a single CPAR for each contract."
5. Who prepares a CPARS on a DO under a GSA contract?
Good question. GSA is currently reviewing their policy on this item. We believe that the people receiving the goods or services are the best qualified to prepare a CPARS and should do so for DOs awarded under GSA contracts--GSA won't know how well the contractor performed. However, they should have a record of performance for future use--which they will get from our activities preparing a CPARS.
In order to enter a CPARS for a GSA contract ("F" order), you should put the GSA 'F' order number where you would put the contract number (Block 4a) and note the GSA contract number in Blk 17, Contract Effort Description. You have to treat the order number (e.g., N451XX-97-F-0001) like the contract number...the reason being that if you enter the GSA contract number, only one person could enter for that contract number for the period.
6. Are overseas contracting offices exempt from CPARS requirements?
This question has arisen both on the basis of the 128-bit encryption requirement and because it is perceived that the need for PPI data on overseas contractors is minimal. The DoN CPARS Guide makes no exceptions from the requirement to prepare CPARS based on location. There are overseas sites utilizing the automated system, so we know it can be done. Any contracting office having difficulties processing automated CPARS should contact NLSC.
Failure to enter completed CPARs records into the CPARS AIS prevents sharing data with other DOD activities. There may be occasions when overseas contractors also do work on Army or Air Force work. This may not be true for shipbuilding contractors but it could apply to machine shops or electrical overhaul facilities, for example. If the completed CPARS are entered into the Navy's CPARS AIS then they become reports of record that can be shared with other agencies either though the AIS or eventually in the DOD PPAIS, which is currently under development.
