OFPP tells agencies to get serious about tracking contractor performance

Monday - 3/11/2013, 4:21pm EDT

The Office of Federal Procurement Policy is attempting, for a third time, to get agencies to use the Past Performance Information Retrieval System (PPIRS) more consistently.

So instead of asking and encouraging, OFPP Administrator Joe Jordan is setting specific goals for agencies.

In a new memo to chief acquisition officers and senior procurement executives, Jordan sets three-year targets for agencies to enter vendor-performance information into the governmentwide database.

This year, the goals vary depending on how often the agency is currently entering data into PPIRS. For instance, departments inputting data for 60 percent or more of their contracts, must improve to 85 percent by Sept. 30. For agencies using PPIRS 30 percent to 60 percent of the time, their goal now is 75 percent. And for those agencies using PPIRS less than 30 percent of the time, their goal is 65 percent.

"This required contract-administration duty can significantly reduce the risk to the government on future awards, so agencies must take bold steps to ensure that all critical performance information is made available in the Past Performance Information Retrieval System (PPIRS) in a timely manner, and to the maximum extent practicable, eliminate duplicative, paper-based past performance evaluation surveys generated outside these systems," Jordan wrote.

By April 5, agencies must:

  • Establish their past performance reporting baseline based on cumulative data from fiscal 2009 to 2012.

  • Set "aggressive" quarterly goals to meet the annual targets and update progress on the OMBMax website.
To help increase use of PPIRS, OFPP worked with the Integrated Acquisition Environment (IAE) to develop a compliance tracking tool for measuring and managing agency reporting on the OMBMax website.

Agency use of PPIRS has been inconsistent over the past decade. In 2011, OFPP analyzed 700 past performance reports and found at best one agency had 63 percent of their ratings and supportive narratives completed, and on the low end, one agency entered only four percent of their contracts into the database.

Additionally, the Government Accountability Office found in 2009 — after reviewing 62 contracts at five of the largest agencies — there was no incentive to use PPIRS so they didn't.

This latest memo is OFPP's third since 2009 regarding past performance. In 2009, OFPP required agencies to do a better job using the system by reinforcing the Federal Acquisition Regulations rule, which required agencies to report past performance information in to the system based on work done under multiple award contracts.

In 2011, OFPP gave agencies more than a dozen steps to take or things to consider to improve past performance data.

Contractor integrity data also under review

OFPP also is encouraging agencies to take other steps to improve reporting of past performance data, including prioritizing high-risk contracts such as time-and- materials and cost-reimbursement types, large dollar contracts and overseas contingency operations procurement.

Additionally, Jordan emphasized the need for workforce training, highlighting classes offered by both the Federal Acquisition Institute and Defense Acquisition University, and the recently-updated Defense Department's Contractor Performance Assessment Reporting System guide.

"Recognizing good performance and holding contractors accountable for poor performance is critical to delivering value to taxpayers," Jordan wrote. "For that reason, OFPP will continue to work with agencies to achieve progress in this area, and will monitor the MAX website quarterly to assess agencies' efforts. OFPP will also hold frequent discussions with the agencies about their reporting progress, and this will continue to be a focus of our future AcqStat sessions."

Along with PPIRS, OFPP wants more agencies and vendors to use the Federal Awardee Performance and Integrity Information System (FAPIIS) to report on whether contractors are breaking the law. Agencies put data into FAPIIS regarding suspension and debarments, defective pricing determinations, non-responsibility determinations and other negative actions.

Vendors are required to certify they have no outstanding criminal convictions, civil liabilities or adverse administrative proceedings.

Data quality still suffering

These new requirements are part of OFPP's efforts to improve the quality of data around federal procurement.

Lesley Field, the deputy OFPP administrator, said at an AFCEA Bethesda breakfast in February that OFPP also will update certification requirements for contracting officers, called the FAC-C in the coming months. It hasn't been updated since 2005.

Field said OFPP will receive recommendations from the Interagency Strategic Sourcing Leadership Council by the end of March detailing management strategies for buying in bulk products and services, including IT commodities.

OFPP already determined 10 common products and services it would like to create strategic sourcing initiatives around.

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