CONTRACTOR 

PERFORMANCE

DOD Actions to 

Improve the Reporting 

of Past Performance 

Information

Report to Congressional Committees

June 2013

GAO-13-589

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-589, a report to 

congressional committees

June 2013

CONTRACTOR PERFORMANCE

DOD Actions to Improve the Reporting of Past 

Performance Information 

Why GAO Did This Study

DOD relies on contractors to perform a 

broad array of activities. Having 

complete, timely, and accurate 

information on contractor performance 

is critical so officials responsible for 

awarding new federal contracts can

make informed decisions. Agencies 

are required to document contractor 

performance for contracts exceeding 

certain dollar thresholds. 

In 2009, GAO found that contractor 

past performance information was 

incomplete, citing low priority and lack 

of system tools and metrics to track 

compliance. In 2011, the Office of 

Federal Procurement Policy (OFPP) 

reported that DOD assessments often 

lacked sufficiently detailed narratives. 

Section 806 of the NDAA for 2012

required DOD to develop a strategy to 

ensure that contractor performance 

assessments are complete, timely, and 

accurate. Section 806 also required 

GAO to report on DOD’s actions and 

their effectiveness. GAO (1) identified 

actions taken by DOD to improve the 

quality and timeliness of past 

performance information and 

implement provisions of the act, and 

(2) assessed the effectiveness of those 

actions. GAO reviewed DOD policy 

and guidance, and interviewed DOD 

and OFPP officials. GAO also 

reviewed available data on compliance 

with reporting requirements from 2011-

2013 and timeliness data for fiscal 

years 2010-2012. GAO did not 

independently assess the quality of 

assessment narratives.

GAO is not making any 

recommendations in this report. DOD 

concurred with GAO’s findings and 

OFPP had no comments.

What GAO Found

The Department of Defense (DOD) strategy for improving the reporting of 

contractor past performance information consists of providing additional training

to its acquisition workforce and developing tools and metrics to improve 

oversight. The number of personnel trained more than doubled since 2010 to 

more than 7,000, and DOD oversight officials now have the ability to track 

compliance with reporting requirements down to the level of individual contracting 

offices. DOD continues to utilize existing past performance guidance, which 

generally aligns with requirements specified in the National Defense 

Authorization Act (NDAA) for Fiscal Year 2012. 

Compliance metrics show that the submission of required assessments has 

increased. Specifically, the percentage of required assessments submitted 

increased from 56 to 74 percent from October 2011 to April 2013. Officials at 

DOD said the ability to track completion of assessments has greatly improved 

oversight and accountability. Despite this progress, DOD faces challenges 

completing assessments on time, as illustrated in the figure below. 

Timeliness of DOD Contractor Performance Assessments, Fiscal Years 2010 through 2012

DOD officials attribute the lack of timeliness to acquisition workforce shortages, 

turnover, and the difficulty in obtaining needed information. DOD is working with 

other agencies on a regulatory change, consistent with a requirement in the 

NDAA for 2012, that would reduce the time allowed for contractors to submit 

comments on draft assessments. This change should help officials submit final 

assessments on a more timely basis.

View GAO-13-589. For more information, 

contact William T. Woods at (202) 512-4841 or 

woodsw@gao.gov
Page i GAO-13-589 Contractor Performance

Letter 1 

Background 3

DOD’s Past Performance Strategy Relies on Workforce Training, 

Enhanced Oversight, and Existing Guidance 5

DOD Increased the Number of Assessments Completed, but Still 

Faces Challenges in Completing Assessments on Time 8

Agency Comments 11

Appendix I GAO Contact and Staff Acknowledgments 14

Tables

Table 1: Percentage of Required Assessments Submitted to the Past 

Performance Information Retrieval System (PPIRS), by 

DOD Component, from October 2011 to April 2013 9

Table 2: Time Frames for Contractor Comments Fiscal Years 2010 

through 2012 11

Figures

Figure 1: Number of DOD Officials Trained on Assessing 

Contractor Past Performance from the Contractor 

Performance Assessment Reporting System (CPARS) 

Program Office by Fiscal Year 6

Figure 2: Timeliness of DOD Assessments Completed Fiscal Years 

2010 through 2012 10

Contents 
Page ii GAO-13-589 Contractor Performance

Abbreviations

CPARS Contractor Performance Assessment Reporting System

DFARS Defense Federal Acquisition Regulation Supplement

DOD Department of Defense 

FAR Federal Acquisition Regulation

NDAA National Defense Authorization Act

OFPP Office of Federal Procurement Policy

PPIRS Past Performance Information Retrieval System

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Page 1 GAO-13-589 Contractor Performance

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Washington, DC 20548

June 27, 2013

Congressional Committees

The Department of Defense (DOD) relies on thousands of contractors to 

perform a broad array of activities needed to meet its mission. Therefore, 

complete and timely information regarding contractor’s past performance 

is critical to ensuring that the government does business with companies 

that deliver quality goods and services on time and within budget. The 

Federal Acquisition Regulation (FAR) requires agencies to document 

contractor performance on contracts that exceed certain dollar thresholds 

and to make such information available to other agencies through a 

shared government-wide database. We reported in 2009, however, that 

the DOD components had completed assessments for less than half of 

the fiscal year 2007 contracts that required such an assessment.1 Agency 

officials noted at the time that a low priority for completing assessments 

and a lack of system tools and metrics to monitor compliance made it 

difficult for managers to ensure timely completion of contractor 

performance assessments. The need to improve both the quantity and 

quality of past performance information also was highlighted in a 2011 

Office of Federal Procurement Policy (OFPP) report that found that DOD 

and other federal agency contractor assessments often lacked quality 

narrative information, such as sufficient details about how the contractor 

exceeded expectations or corrected poor performance, to support the 

assessment. According to OFPP, some of the deficiencies identified were 

likely due to staff shortages and the lack of training.

Section 806 of the National Defense Authorization Act (NDAA) for Fiscal 

Year 2012 required DOD to develop a strategy for ensuring that 

contractor past performance assessments are complete, timely, and 

accurate.2 Section 806 outlines several requirements related to 

documenting contractor performance and obtaining contractor comments 

on performance assessments. In addition, section 806 also requires the 

Defense Federal Acquisition Regulation Supplement (DFARS) to be 

revised to require that contractor assessments be posted to the 

 

1 GAO, Federal Contractors: Better Performance Information Needed to Support Agency 

Contract Award Decisions, GAO-09-374 (Washington D.C.: Apr. 23, 2009).

2 Pub. L. No. 112-81 § 806 (2011).

 
 

Page 2 GAO-13-589 Contractor Performance

databases used for making source selection decisions no later than 14 

days after delivery of the performance assessment to the contractor.3 The 

act also mandates us to report on DOD’s actions to implement the 

required provisions. For this report, we (1) identified the actions taken by 

DOD to improve the quality and timeliness of past performance 

information and implement provisions of the act, and (2) assessed the 

effectiveness of those actions.

To identify DOD’s actions to improve the timeliness and quality of 

contractor past performance information and implement provisions of the 

act, we reviewed DOD policy and guidance related to contractor 

assessments. We also interviewed DOD officials responsible for 

contractor past performance information at the Office of the Under 

Secretary of Defense for Acquisition, Technology, and Logistics; the three 

DOD components—the Air Force, Army, and Navy— which account for 

more than 90 percent of DOD’s required assessments; and the 

Contractor Performance Assessment Reporting System (CPARS) and 

Past Performance Information Retrieval System (PPIRS) program offices 

to discuss actions taken or planned.4 We also interviewed DOD and 

OFPP officials to discuss the status of implementing the requirement to 

submit contractor assessments to the past performance database within 

14 days. To assess the effectiveness of DOD’s past performance efforts, 

we reviewed data for calendar years 2011 to 2013 for compliance with 

contractor assessment requirements. To assess the reliability of these 

data, we reviewed system information and tested the processes and 

found these data to be sufficiently reliable for the purpose of this report. In 

addition, we obtained data for fiscal years 2010, 2011, and 2012 on the 

number of DOD contracting officials that received training on contractor 

past performance reporting and the timeliness of performance 

assessments. We also reviewed an OFPP report on compliance with 

reporting requirements and quality of assessments. We did not 

independently assess the quality of contractor performance assessment 

narratives or the use of contractor past performance information in the 

source selection process.

 

3 Agencies are required to submit past performance reports electronically to the Past 

Performance Information Retrieval System (PPIRS). FAR § 42.1503(c).

4 Both CPARS and PPIRS are managed and maintained by DOD’s Naval Sea Logistics 

Center Portsmouth but are government-wide systems under the direction of the General 

Services Administration’s Integrated Acquisition Environment. 
 

Page 3 GAO-13-589 Contractor Performance

We conducted this performance audit from February 2013 to June 2013 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

When selecting contractors, the FAR requires agencies to consider past 

performance as one evaluation factor in most competitive procurements.5

During the source selection process, contracting officials often rely on 

various sources of past performance information, such as the prospective 

contractor’s prior government or industry contracts for efforts similar to 

the government’s requirements, and the past performance information 

housed in the government-wide PPIRS database.

Once a contract is awarded, the agency should monitor the contractor’s 

performance throughout the performance period. At the time the work is 

completed, the FAR requires agencies to prepare an assessment of the 

contractor’s performance for contracts or orders that exceed the simplified 

acquisition threshold.6 DOD has dollar thresholds that are generally 

higher than the simplified acquisition threshold for contractor 

assessments, which vary based on business sector.

To document and manage contractor performance information internally, 

DOD has used CPARS since 2004. The system, which was developed by 

the Navy, incorporates processes and procedures for drafting and 

finalizing assessments, which are described in the CPARS Guide. The 

assessing official rates the contractor based on various elements such as 

quality of product or service, schedule, cost control, business relations, 

 

5 Past performance must be considered in selecting contractors for negotiated competitive 

procurements expected to exceed the simplified acquisition threshold, unless the 

contracting officer documents the reason past performance is not an appropriate 

evaluation factor for the acquisition. FAR § 15.304(c)(3). Evaluation of past performance, 

for example, may not be appropriate in a “lowest price, technically acceptable” source 

selection. FAR §15.101-2(b)(1). 

6

FAR § 42.1502 (a), (b) and (c). Currently, the dollar threshold for simplified acquisitions, 

with limited exceptions, is $150,000. FAR § 2.101. The FAR has separate thresholds of 

$650,000 and $30,000 for construction and architect-engineer services contracts 

respectively. FAR § 42.1502(e) & (f). 

Background 
 

Page 4 GAO-13-589 Contractor Performance

small business utilization, and management of key personnel. For each 

applicable rating element, the assessing official determines a rating 

based on definitions in the CPARS Guide that generally relates to how 

well the contractor met the contract requirements and responded to 

problems. In addition, for each rating element, a narrative is required to 

provide examples and support for the assessment. 

Once draft assessments are completed by the assessing official, the 

contractor is notified that the assessment is available for their review and 

comment through CPARS. The comment process includes the following:

• Contractors are allowed a minimum of 30 days to provide comments, 

rebuttals, or additional information.7 The assessing official has the 

discretion to extend the comment period.

• The contactor can request a meeting with the assessing official to 

discuss the assessment or request a review by the reviewing official. 

• After receiving and reviewing a contractor’s comments and any 

additional information, the assessing official may revise the 

assessment and supporting narrative.

• If there is disagreement with the assessment, the reviewing official—

generally a government official one level above the assessing official 

organizationally—will review and finalize the assessment.

After contractor comments are considered, or if the contractor elects not 

to provide comments, the assessment is finalized and submitted to 

PPIRS, where it is available government-wide for source selection 

purposes for 3 years after the contract performance completion date.8

Section 806 of the NDAA for Fiscal Year 2012 required DOD to develop a 

strategy for improving contractor past performance information to include 

standards for timeliness and completeness, assigning responsibility and 

accountability for completing assessments, and ensuring assessments 

are consistent with award fee evaluations. In addition, the section 

 

7 Providing contractors a minimum of 30 days to respond is required by the FAR § 

42.1503(b). 

8

Construction and architect-engineer contracts are available for 6 years after the contract 

performance completion date. FAR § 42.1503(e).
 

Page 5 GAO-13-589 Contractor Performance

requires the DFARS to be revised to require contractor assessments to 

be posted to databases used for making source selection decisions no 

later than 14 days after delivery of the draft assessment to the 

contractor.9

DOD’s strategy to improve reporting of contractor past performance 

information and respond to section 806 of the NDAA for Fiscal Year 2012 

is to provide training on past performance to acquisition officials, develop 

tools and metrics to track compliance and enhance oversight, and 

continue to rely on the CPARS Guide. Some elements of this strategy are 

in place already, while others are still in progress.

In order to improve compliance with past performance reporting 

requirements and the quality of assessments, the CPARS program office 

provides training opportunities and assessment tools for acquisition 

officials. As a result of increased emphasis on training, the number of 

contracting officials trained on contractor past performance more than 

doubled from fiscal year 2010 to fiscal year 2012, as shown in 

figure 1.

 

9

The FAR currently requires that contractors are provided a minimum of 30 days to 

provide comments. Rather than establishing a DOD class deviation from the FAR, the 

FAR Council, which includes DOD, agreed to implement the change government-wide by 

developing a proposed change to the FAR. As part of the rulemaking process, the 

proposed rule is under review by the Office of Management and Budget before being 

released for public comment, which OFPP officials estimate will occur around mid 2013.

DOD’s Past 

Performance Strategy 

Relies on Workforce 

Training, Enhanced 

Oversight, and 

Existing Guidance

Training on Past 

Performance 

Requirements
 

Page 6 GAO-13-589 Contractor Performance

Figure 1: Number of DOD Officials Trained on Assessing Contractor Past 

Performance from the Contractor Performance Assessment Reporting System 

(CPARS) Program Office by Fiscal Year

Training included on-site classes; instructor-led, web-based training; and 

most recently, automated on-line training. Courses include overviews, 

and training on how to write quality narratives supporting contractor 

assessments. In addition, the CPARS program office provides tools to 

facilitate completing assessments, including a quality checklist which 

includes best practices and guidance for writing sufficiently detailed 

narratives. We did not assess the quality of assessment narratives in this 

review.

To increase management oversight of contractor performance 

assessments, the CPARS program office in 2010, in conjunction with 

OFPP, developed system tools and metrics within PPIRS to track 

compliance with the reporting requirements. This allows managers to 

track compliance at the department, component, or contracting office 

level. For example, contracting managers can identify overall compliance 

for their office and identify specific non-compliant contracts with this new 

tracking tool.

Tools and Metrics Allow 

for Increased Oversight
 

Page 7 GAO-13-589 Contractor Performance

Officials at DOD components told us that having the ability to track 

completion of required assessments through PPIRS has greatly improved 

the ability to effectively oversee and manage compliance, and has also 

improved accountability for completing assessments. In an effort to 

increase accountability, the Director of Defense Procurement and 

Acquisition Policy issues quarterly compliance reports to senior 

procurement executives. Senior procurement executives at DOD 

components have required reporting of actions taken by individual 

contracting activities, set goals for compliance, and encouraged or 

required training. In addition, DOD officials told us contractor past 

performance is now discussed at senior level acquisition quarterly and 

monthly meetings.

DOD plans to continue implementing existing policies contained in the 

CPARS Guide, which addresses most of the required elements specified 

in section 806. Specifically, the CPARS Guide aligns with section 806 

through the following:

Standards for timeliness:

• Contractor performance assessment must be finalized within 120 

days after the end of the evaluation period. For contracts and orders 

with performance exceeding one year, annual interim assessments 

are required and a final assessments is required when the work is 

completed.10

Roles and responsibilities for documenting contractor performance:

• The assessing official, usually the contracting officer, is responsible 

for preparing and finalizing the assessment.

• The reviewing official reconciles any disagreements between the 

assessing official and the contractor.

• The CPARS Focal Point provides overall support for the CPARS 

process for a particular organization and assigns key roles for each 

contract requiring an assessment based on information from the 

contracting officer, program, or project manager.

 

10 CPARS Guide, page 14, para. 4.1.1 (November 2012).

CPARS Guide Addresses 

Most of the Elements in 

Section 806
 

Page 8 GAO-13-589 Contractor Performance

Award fee guidance:

• Provides sources of data to consider, including earned incentive and 

award fee determinations. In addition, DOD provided additional 

guidance on translating award fee determinations into past 

performance assessments. 

Although the CPARS Guide does not currently specify standards for 

completeness, one of the elements specified in section 806, a recent 

proposed change to the FAR will address completeness by providing 

minimum government-wide standards for past performance rating 

elements. Specifically, the proposed rule requires that all assessments 

address, at a minimum, quality of product or service, timeliness, and 

management or business relations.11

PPIRS compliance metrics show the percentage of required assessments 

completed increased from 56 percent in 2011 to 74 percent in 2013. In 

addition, the number of assessments completed overall more than 

doubled from 2010 to 2012. DOD still faces challenges, however, in 

completing assessments on time.

An increased focus on completing past performance assessments, both 

within the components and among individual contracting activities, has 

resulted in more required assessments being completed and submitted to 

PPIRS. As of April 2013, PPIRS’s metrics show compliance with the 

reporting requirement of about 74 percent—an increase of 18 percentage 

points since October 2011. Based on our review of government-wide 

PPIRS compliance metrics, DOD compliance with the reporting 

requirement is generally much higher than other federal agencies. For 

example, as of April 2013, more than half of federal agencies had no 

required contractor assessments in PPIRS. Among DOD’s major 

 

11 FAR Case 2012-009. 77 Fed. Reg. 54864,54869 (Sept. 6, 2012).

DOD Increased the 

Number of 

Assessments 

Completed, but Still 

Faces Challenges in 

Completing 

Assessments on Time

Submission of Required 

Assessments Has 

Increased
 

Page 9 GAO-13-589 Contractor Performance

components, most showed significant improvement, as shown in table 1 

below.

Table 1: Percentage of Required Assessments Submitted to the Past Performance 

Information Retrieval System (PPIRS), by DOD Component, from October 2011 to 

April 2013

DOD Component 

Compliance ratea as of

Oct. 3, 2011 Sep. 28, 2012 April 1, 2013

Air Force 82% 82% 80%

Navy 66 69 72

Army 49 60 73

Other DOD 32 61 71

Total DOD 56% 66% 74%

Source: PPIRS compliance metrics.

a

Compliance is based on contracts or orders that should have an assessment in PPIRS—that is, with 

a period of performance over the prior 3 years that meet the reporting dollar threshold, and have an 

assessment due.

Although compliance with the reporting requirements for performance 

assessments has increased, DOD still faces challenges with completing 

assessments on time. As shown in figure 2, the total number of 

assessments completed more than doubled from 2010 to 2012. In 

addition, the number of assessments completed on time also increased 

significantly—from about 5,600 to almost 14,000. However, the majority 

of assessments completed each year exceeded the 120-day standard for 

timeliness. In part, the number of assessments completed after the 

specified time frame may be the result of increased emphasis on working 

down the backlog of past-due assessments. For example, about 31,000 

assessments became due during fiscal year 2012, but DOD completed 

over 33,000 during that year.

Timeliness of Submissions 

Remains a Challenge
 

Page 10 GAO-13-589 Contractor Performance

Figure 2: Timeliness of DOD Assessments Completed Fiscal Years 2010 through 

2012

DOD officials told us that department-wide acquisition workforce 

shortages and turnover, as well as difficulty obtaining contractor 

performance information remain as challenges to completing contractor 

performance assessments on time. For example, completing contractor 

assessments is considered a joint responsibility between the contracting 

and program office and, the assessing official often relies on others to 

provide information needed to complete the assessment, and in some 

cases may have difficulty obtaining the information.

In addition, assessments are not finalized until the contractor has an 

opportunity to provide comments, and the 120-day standard for finalizing 

assessments includes the contractor comment period. The FAR currently 

requires that all federal contractors be given a minimum of 30 days to 

submit comments, rebutting statements, or additional information to 

performance assessments. As shown in Table 2, DOD received 

comments from contractors on over 80 percent of all assessments from 

fiscal years 2010 through 2012, and most were received within the 

current 30-day minimum requirement for responding.
 

Page 11 GAO-13-589 Contractor Performance

Table 2: Time Frames for Contractor Comments Fiscal Years 2010 through 2012

Percentage of 

completed 

assessments

Contractor comments 

received

14 days or less 43

Between 14 and 30 days 30

Greater than 30 days 9 

Total assessments with comments 81

Contractor comments

not received 

Assessment finalized and submitted to 

PPIRS without comments 19

Source: Contractor Performance Reporting System (CPARS) Program Office. 

Section 806 would limit the comment period to 14 days before the 

assessment is submitted to PPIRS, which should help DOD meet the 

120-day standard for submitting past performance assessments. DOD is 

currently working with the rest of the FAR Council to implement this 

change.

We are not making recommendations in this report. We provided a draft 

of this report to DOD and OFPP for their review and comment. DOD 

informed us by email that it concurred with our findings and the 

information presented in this report and would not be providing written 

comments. DOD officials provided technical comments, which we 

incorporated as appropriate. OFPP informed us by email that the office 

had no comments.

We are sending copies of this report to appropriate congressional 

committees, the Secretary of Defense, the Under Secretary of Defense 

for Acquisition, Technology, and Logistics, the Director of the Office of 

Management and Budget, and other interested parties. This report will 

also be available at no charge on the GAO website at http://www.gao.gov.

Agency Comments
 

Page 12 GAO-13-589 Contractor Performance

If you or your staff have any questions about this report, please contact 

me at (202) 512-4841 or woodsw@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix I.

William T. Woods

Director, Acquisition and Sourcing Management
 

Page 13 GAO-13-589 Contractor Performance

List of Committees

The Honorable Carl Levin

Chairman

The Honorable James M. Inhofe

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Dick Durbin

Chairman

The Honorable Thad Cochran

Ranking Member

Subcommittee on Defense

Committee on Appropriations

United States Senate

The Honorable Howard P. “Buck” McKeon

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

The Honorable C.W. Bill Young

Chairman

The Honorable Pete Visclosky

Ranking Member

Subcommittee on Defense

Committee on Appropriations

House of Representatives
Appendix I: GAO Contact and Staff 

Acknowledgments

Page 14 GAO-13-589 Contractor Performance

William T. Woods, (202) 512-4841 or woodsw@gao.gov

In addition to the contact named above, LaTonya Miller, Assistant 

Director; John Neumann, Assistant Director; Dani Green; Julia Kennon; 

John Krump; and Bradley Terry made key contributions to this report.

Appendix I: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Staff 

Acknowledgments 

(121104)
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