DATE: June 13, 2000

FROM: Barry McVay, CPCM

SUBJECT: Office of Federal Procurement Policy (OFPP); Best Practices for Collecting and Using Current and Past Performance Information

SOURCE: Acquisition Reform Network Library, June 5, 2000

AGENCIES: Office of Federal Procurement Policy (OFPP), Office of Management and Budget (OMB)

ACTION: Notice

SYNOPSIS: On June 5, 2000, OFPP published the May 2000 "Best Practices for Collecting and Using Current and Past Performance Information," which replaces the May 1995 "A Guide to Best Practices for Past Performance." Where the May 1995 publication concentrated on the use of past performance information in the evaluation of proposals, the new publication also concentrates on gathering current performance information for proposal evaluations and for "maintaining high quality performance or improving inadequate performance."

EDITOR'S NOTE: The guidebook is available on the Internet at http://www.arnet.gov/Library/OFPP/BestPractices/pastpeformguide.html.

FOR FURTHER INFORMATION CONTACT: For hard copies, or for questions, comments, or suggestions, contact David Muzio, 202-395-6805, fax: 202-395-5105, e-mail: dmuzio@omb.eop.gov or Yvette Garner, 202-395-7187, e-mail: ygarner@omb.eop.gov.

SUPPLEMENTAL INFORMATION: Since the enactment of the Federal Acquisition Streamlining Act of 1994 (Public Law 103-355) (FASA), past performance has been a required evaluation factor in awards over certain amounts (phased-in to the current $100,000). Contract performance information has been gathered for this purpose, but using on-going contract performance information to apprise the contractor of its performance has not been stressed. This revised "Best Practices" guide emphasizes that such information can, and should, be used to keep contractors informed so they can maintain or improve their performance. However, "the techniques and practices used to implement the current and past performance initiatives that are discussed in this document are not mandatory regulatory guidance." In fact, most of the guide reiterates and elaborates upon the requirements contained in Federal Acquisition Regulation (FAR) Subpart 15.3, Source Selection, and FAR Subpart 42.15, Contractor Performance Information.

"Commercial companies have come to recognize that two-way communication is vital to a productive relationship with their suppliers," the guide states in the introduction. "On-going open discussion with the contractor about the Government's requirements and how the contractor can best meet them, can greatly improve the quality of deliverables under Government contracts."

The contents of the guide are as follows:

Chapter 1, Introduction
Chapter 2, Evaluating and Recording Current Performance
Chapter 3, Using Current and Past Performance as a Source Selection Factor
Appendix I, Sample Contractor Performance Report and Instructions
Appendix II, DOD [Department of Defense] Performance Assessment Elements for Large Systems
Appendix III, Performance Rating Guidelines
Appendix IV, Sample Questions and Ideas for Telephone Interviews and Questionnaires
Appendix V, Automated Past Performance Information Systems

The following advice and comments are contained in the guide:

Chapter 1, Introduction

Chapter 2, Evaluating and Recording Current Performance

Chapter 3, Using Current and Past Performance as a Source Selection Factor

EDITOR'S NOTE: In meetings with OFPP, contractors expressed concerns that many assessments are being done inconsistently or not at all. OFPP seems to believe (or at least hope) that this Best Practices publication will provide the guidance that has been lacking up to this point. The information and suggestions are practical and useful. But look at the coverage in the FAR -- it is pitifully puny. The May 1995 version of the guide included a requirement that such assessments be performed, but its five years of existence have not changed the situation much. Until these "suggestions" are put in the FAR, do not expect any sweeping contract administration transformations.

FOR FURTHER INFORMATION CONTACT: Barry McVay at 703-451-5953 or by e-mail to BarryMcVay@FedGovContracts.com.

Copyright 2000 by Panoptic Enterprises. All Rights Reserved.

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