Leaning in for CPARS Excellence
In the world of federal contracting, “satisfactory” is a dirty word. The goal for U.Group—and most other companies that work with the federal government—is to have our efforts recognized as exceptional. These two words are more than superlatives, though. They’re designations recorded in the Contractor Performance Assessment Reporting System (CPARS).
Why is it so important to be rated as exceptional? It feels good, for starters. There’s more to it than that, however. An exceptional rating enhances our competitiveness for future business opportunities. It also provides objective feedback that can accelerate future performance excellence.
Given the importance of your CPARS rating, it is critical to understand in what context and how your performance is measured. This gives you an opportunity to shape the rating produced. In this article, we’ll go over the ins and outs of CPARS and how you can optimize your scores.
Understanding the Context of CPARS Ratings
Contractors face challenges to earning high ratings. Several CPARS ratings are biased toward “satisfactory,” and timeliness on the government’s part is often a challenge. Individuals responsible for accomplishing the ratings may change and may not be responsive when assessments are being processed. Short CPARS suspenses and workload may pressure assessing officials to write off a quick satisfactory assessment instead of taking the time to justify a very good or exceptional rating.
Worse yet, contractors are given a limited opportunity to contest a rating. It is also not optimal to argue with a reviewing official at the eleventh hour if you forgo the opportunity to influence actual performance and the appreciation of it earlier. If you are going to have those conversations you’ll need to understand some system parameters.
When performance is measured
CPARS is not routinely required for every contract. For civilian agencies, contract writing systems generally populate CPARS with a requirement to report performance for systems and non-systems contracts valued greater than the Simplified Acquisition Threshold (currently $250,000).
For defense agencies, the threshold is generally $5,000,000—but it’s $1,000,000 for some information technology and operations support requirements. When requirements are critical or when performance is extremely good or bad, an assessing official may decide to manually establish a CPARS record.
On multi-year contracts, assessments are generally provided annually as interim evaluations and as a final evaluation at the end of the performance period. Interim evaluations and final evaluations are not cumulative, and each evaluation period is an independent assessment.
How performance is measured
There are several evaluation factors that go into a CPARS rating. These factors include:
- Technical (for the quality of the service or product)
- Cost control (for contracts that are not firm-fixed-price)
- Management or business relations
- Small business subcontracting (when subcontracting plans are required)
- Other (as applicable)
Evaluation subfactors may be used, and on cost-plus or award-fee contracts those evaluations are also entered. CPARS defines five levels of ratings, with a separate definition for small business subcontracting ratings, and there is a specific guidance to justify the assignment of rating levels. The CPARS evaluation ratings can be viewed at FAR 42.1503 at Table 42-1—and at Table 42-2 for small business subcontracting. This is a brief summary of each rating level:
- Exceptional. Performance must exceed several contractual requirements to the government’s benefit—or have a single, exceptionally significant benefit. There should be no significant weaknesses identified.
- Very Good. Performance should meet requirements and exceed them in some areas. A significant event that benefits the government should be identified, and there should be no significant weaknesses.
- Satisfactory. Performance should meet contractual requirements. There should only have been minor problems, and no significant weaknesses identified. A fundamental principle of assigning ratings is that contractors will not be evaluated with a rating lower than Satisfactory solely for not performing beyond the requirements of the contract/order.
- Marginal. Performance does not meet some contractual requirements, and they reflect a serious problem for which the contractor has not yet identified corrective actions. Contractor actions were either marginally effective or not fully implemented.
- Unsatisfactory. Performance fails to meet most contractual requirements, and recovery is unlikely to be accomplished in a timely manner. There were serious problems, and the contractor’s corrective actions were ineffective.
How to Optimize CPARS Ratings
To merit exceptional ratings, you’ll need to do your homework so that you understand the CPARS framework and the type of justifications needed to support the desired ratings. You already understand the technical requirements or you would not have received the award, but enhancing your performance takes more than that. You need to be an expert in your understanding of FAR Subpart 42.15, CPARS User Manual and guidance, and training resources, as well.
As early as possible after contract award, you need to engage with the contracting officer and the contracting officer’s representative in a post-award conference to review performance requirements, outline what is needed to satisfy contract requirements, and listen to feedback. In our case at U.Group, this is when we take the opportunity to share that U.Group has a corporate commitment to exceed those expectations and deliver exceptional performance, within scope. When carving out the details of your commitment, consider the following:
- Frame your commitment in terms of significant milestones and realistic capabilities you intend to deliver that would provide additional benefit to the government
- Make a commitment to be responsive to performance feedback and provide service standards to manage expectations
- Have a goal, or incremental goals, about a singular benefit that you can deliver
- Document this performance for each of the rating factors in language that reflects exceptional performance
With this framework in place, meet with and share it with the government officials regularly. Ask if they concur that your performance is not only satisfactory but on track to exceed their expectations. Providing this documentation in a post-meeting email summary makes it easier for assessing officials to rate your performance as exceptional and provides documentation for reviewing officials to consider when proposed ratings fall below expectations.
What to do if you don’t agree with your rating
When you receive ratings that do not reflect your commitment to excellence, you have 60 days to review and comment. This includes an opportunity to disagree objectively with proposed ratings by offering the singular benefits of your performance. If you do not provide comment within the allotted timeframe, the government will complete the assessment. If you provide comment within the first 14 days the assessment can be closed and used for source selection.
The reviewing official must ensure that the evaluation is a fair and accurate assessment of your performance for the specific contract/order and performance period. They must acknowledge consideration of any significant discrepancies between the assessing official’s evaluation and the contractor’s remarks. This is the final opportunity where your periodic discussions and documentation of performance can influence the outcome and record of performance.
Don’t Be Shy
If you find yourself worrying about bell curve distributions of performance assessments, you needn’t worry about comparing your performance to other contractors. A number of potentially lesser performing contractors didn’t even receive awards. Satisfactory performance is assessed against what it takes to comply with the statement of work—not against the performance of others.
Acknowledging actual performance that is exceptional, in terms defined by CPARS, enables the government to continue to partner with the best performers. Performance, particularly CPARS ratings, are a mandatory consideration for future award determinations. So now that you know how CPARS ratings work—and how to optimize your organization’s ratings—you’re ready to position yourself as one of the exceptional contractors out there.