If the federal acquisition workforce is ever going to make contractor evaluations meaningful, it’s going to happen this year.
The General Services Administration and Department of Homeland Security are offering two different, but equally important initiatives that either will prove that the federal community cares about past performance as a key evaluation factor or has been playing lip service to the issue since 2009.
Over the past 11 years, successive memos from the Office of Federal Procurement Policy encouraging agencies to do more research and evaluation of contractor performance on contracts have had little impact.
“We think there is a clear appetite for Contractor Performance Assessment Reporting System (CPARS), but contracting officers and industry also know the current CPARS process is broken. I think OFPP hears it from contracting officers that it’s burdensome, and they hear from contractors that it’s not resulting in fair and accurate ratings,” said Mike Smith, a former DHS director of strategic sourcing and now executive vice president at GovConRx, which has been leading the effort to revamp CPARS for much of the past two years or more. “Agencies can use CPARS data to strategically manage procurements, but there needs to be wholesale relook at it. We need to make sure it results in good information and the information is more strategic and tactically used.”
DHS and GSA will see firsthand this year if that appetite is strong enough to address the systemic problem of CPARS — too many contracting officers are saying a vendor’s performance is satisfactory for two main reasons: A lack of time to explain why the contractor was outstanding or exceptional, and to avoid any lengthy back-and-forth if a rating is below average or poor.
AI pilot in phase 2
DHS is trying to address these shortcomings by applying artificial intelligence tools to the CPARS process.
Its program is in the middle of phase 2 where five companies are building a production ready software tool. DHS awarded these companies — IBM, CORMAC, True tandem, Strongbridge and Hangar — $125,000 to demonstrate their technologies this year.
“The user community will take a look during these demos to make sure they feel like they are trustworthy solutions. We want the value to be proved out,” said Polly Hall, director of DHS’s Procurement Innovation Lab (PIL). “The demos are focusing on harder issues. They built these to be commercial solutions and using software-as-a-service (SaaS). We don’t want the federal government to buy the AI and own it. We want to buy licenses and for the tools to ingest the information and present it to us in way that is useful.”
DHS and nine agency partners — the departments of Commerce, Energy, Interior, Veterans Affairs and Health and Human Services, GSA, NASA, the Air Force and the U.S. Agency for International Development — are reviewing the pilot. The agencies gave the five companies 50,000 procurement records, which they anonymized, to help train the AI.
Hall said by July DHS and its partners will decide which of the technologies should move into phase 3 and will get the software tools an authority to operate in time to launch January.
“If we can solve some of the challenges with policy and security accreditation, we will move into phase 3 where the agency partners will test the technologies on actual solicitations. They still will do a human review, but also bring in the AI solution and compare them on real procurements to validate and compare,” she said. “The final phase would be to move into full production, and maybe create a governmentwide contact so agencies can choose which tool they want to use.”
Hall said offering the AI tools as a shared service is another possibility. She said the more agencies that use the tools, the lower the cost will be and the more value it will provide all agencies.
She said the contracting officers who have tested out the AI tools have found them valuable.
“We are cautiously optimistic and we believe everyone will see the value. This is the year where our hard work comes to bear and we either get it or not,” she said. “We need our partners and OFPP to step up and work with us to make this happen. We feel good that there has been a lot of discussions with agency CIOs and at the governmentwide level about getting through the challenges of the ATO and about addressing the hard policy issues.”
New memo promoting self-assessments
For GSA, it’s a matter of whether contracting officers pick up on the ability for vendors to provide self-assessments on specific projects.
GSA senior procurement executive Jeff Koses issued a memo in February promoting the use of vendor self-assessments as one step in the overall CPARS process.
This is something Smith and GovConRx have been promoting for the past few years.
Jim Williams, a former federal executive with GSA, the IRS and the Department of Homeland Security, and now a principal with Williams Consulting, LLC and an advisor for GovConRx, said contractors feel they aren’t being judged fairly and have no input into the process. He said the GSA memo is a permission slip for contracting officers to start asking for a self-assessment as part of the broader CPARS process.
“We believe this will give CPARS more balance because of the input by contractors, and it will alleviate burden on contracting officers. It will produce a more accurate and fair rating,” he said.
Williams and Smith say the self-assessment would be just one piece to the puzzle, but would open the door to a wider conversation, similar to an employee doing a self-assessment for their boss. Smith said this self-assessment approach is common in the human resources sector, and no reason the same approach can’t be used by the acquisition workforce.
“Contractor self-assessments can save time while allowing contractors the opportunity to make their case about their performance. Getting the contractor’s point of view early on in the process may reduce the back and forth during the 60-day period contractors have to respond to a CPARS notification following the assessing official’s evaluation in the system,” Koses wrote in the memo. “A contractor actively tracking its performance may have fewer performance issues. If nothing else, editing someone else’s work is much easier and faster than creating an evaluation from scratch.”
OFPP needs to get more involved
GSA recommended contracting officers use the contract kickoff meeting after award to have initial discussions about self-assessments so the contracting officers can track performance during the full life of the program and correct any issues on an ongoing basis.
“The memo is a good first step for GSA. We would like to see OFPP issue something on a more governmentwide basis that encourages the use of contractor self-assessments,” Smith said. “You wouldn’t believe how many contracting officers refuse to take input from industry because they think they aren’t allowed to. As a contacting officer, I’d rather have a back and forth at least by midyear, if not before, so we can adjust course and have a common understanding at the end of the performance period and there are no surprises about ratings and the basis of that rating.”
Williams added that good contractors will jump at the opportunity to do a self-assessment because they will finally be able to have input into the process.
“We think this will help small businesses particularly because when contracting officers see they have done larger jobs and done them well through relevancy search and high CPARS, then they are more likely to feel comfortable with awarding them a contract,” he said. “It also will help contracting officers because they will make better decisions through data, use it as a tool to have discussions that can also be used at the task order level.”
If both initiatives turn out to be successful over the next year, it’s time for OFPP to not just issue another memo but mandate its use and actively promote its use through the frontline forum, at industry events and on Capitol Hill. And they shouldn’t wait until there is a confirmed OFPP administrator.