Experienced contractors understand the importance of positive contract past performance assessments and strive to ensure that successful contract efforts are accurately reflected in the Contract Performance Assessment Report System (“CPARS”) and the Past Performance Information Retrieval System.  An August 7 Report by the Government Accountability Office (“GAO”), however, highlights the struggles of federal agencies to properly report contract past performance information.

The GAO Report found that while agencies have taken some positive steps to improve their reporting of contractor past performance information, federal agencies are still falling far short of the reporting compliance targets set by the Office of Federal Procurement Policy (“OFPP”) in March 2013.  OFPP set tiered compliance requirements for FY 2013, 2014, and 2015, giving agencies time to achieve 100% reporting compliance by FY 2015.  However, as the excerpted chart below illustrates, federal agencies are falling well short of the 100% reporting target.

While the GAO Report did not make any recommendations, it did note that steps are being taken to improve reporting compliance, including the issuance of the government-wide CPARS Guide in November 2012. Unfortunately for contractors, the GAO Report notes that one of the major steps being taken to improve compliance is to drastically decrease the amount of time contractors are afforded to provide comments on a CPARs report.  The FAR Council’s recent amendment to FAR 42.1503, implementing section 853 of the 2013 National Defense Authorization Act, reduced the contractor response period from 30 days to 14 days effective July 1, 2014. By taking time away from the contractor, the cognizant agency would have additional time to meet its 120-day deadline under the CPARS Guide.