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PPI Collection

Active Collection.  An agency may solicit PPI from any source, even if it is not listed as a reference.  It can include nearly anything a CO deems relevant that is consistent with the solicitation.  Also, evaluation need not be provided by any specific person as long as they have specific knowledge of the contract.  A protest was rejected where a project engineer, rather than the referenced individual in the proposal, asserted unfavorable and subjective comments. The GAO ruled not only was it sufficient the agency contacted a person with specific knowledge of the contract but also there was no duty to conduct further investigation.

Passive Collection.  FAR 42.15 specifies agencies must prepare an evaluation of contract performance for each contract in excess of $100,000 at the time work is completed.  Interim evaluations are also called for when periods of performance exceed one year.  The FAR, however, does not specify what factors of performance must be evaluated or what information collected, leaving past performance evaluation to the complete discretion of each agency.  The most recent guidance from DOD seeks consistent information but it fails to set forth a required format.

The only exception to this broad discretion are construction and architecture/engineering contracts.  For construction, past performance evaluation are prepared using Standard Form 1420 for contracts exceeding $500,000 which evaluates quality of work, timely performance, effectiveness of management and compliance with labor and safety standards.  For A&E contracts over $25,000, SF1421 is used to evaluate accuracy, completeness, cooperation, coordination, management, meeting schedules, personnel abilities and work quality.

Automated Collection.  To permit more efficient sharing of PPI across agencies, some are automating their PPI which results in standardized formats for collection to the extent different agencies use the same system.  The Contractor Performance System (CPS) of the National Institute of Health has evolved into a shared file system now being used by 42 agencies including HHS, Agriculture, Commerce, Justice, Treasury, AID, EPA and the NRC.  The CPS collects numerical ratings (0-5) and supportive narratives addressing quality, cost control, timeliness, business practice, subcontracting goals and performance, key personnel and commitment to customer service.  DOD is also now developing a system designed to link its various departments and services.

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To discuss your needs, contact Bill Lennett, Principal, at 1-925-362-0712 or email him at This e-mail address is being protected from spam bots, you need JavaScript enabled to view it .

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