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R.I.P. PPIRS

First things first: sorry about the title of this article.
How contractor past performance information used to flow from CPARS through PPIRS and into FAPIIS.

The longer, alternate title would have been “Rest In Peace – the Past Performance Information Retrieval System Sleeps with the Fishes.” But that doesn’t have the same kind of obscure, punchy, epitaph-type quality that I’m aiming for. So instead, we give you get a garbled mess of an acronym to remind us that the Past Performance Information Retrieval System (PPIRS) – the system once used by the U.S. Government to house the final performance assessments for government contractors – is no more. As far as epitaphs go, most of us would agree that “R.I.P.” is just about what an acronym deserves.

There are various “past performance” reporting and accountability systems for contractors, including the Contractor Performance Assessment Reporting System (CPARS) (dating back to around 2007), PPIRS (first introduced around 2009), and the Federal Performance and Integrity Information System (FAPIIS) (finalized in early-2010).  There is a neat little picture to help demonstrate how data flowed through the various governmental systems.

These systems continue to evolve, and PPIRS is officially no more – formally rolling into CPARS. And, in time, CPARS will be no more, eventually rolling into the multi-functional, highly integrated, federal System for Award Management (SAM), available at SAM.gov (and currently available in a semi-upgraded fashion at beta.SAM.gov).

Keep reading this article at: https://www.natlawreview.com/article/rip-ppirs

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DHS wants AI to improve the contract performance assessment reporting system

The Homeland Security Department (DHS) wants proofs or viable prototypes that demonstrate how artificial intelligence can support contracting officers as they conduct past performance evaluations and make effective use of data from the Contract Performance Assessment Reporting System (CPARS), according to a solicitation on the FedBizOpps website. 

Run through the department’s commercial solutions opening pilot program to competitively procure innovative items, the solicitation was originally posted in early August but amended this week to include the government’s answers to submitted questions.

“An AI solution for CPARS may significantly assist contracting officers conducting past performance evaluations by identifying relevant past performance assessment records in a more accurate, consistent, faster and useful manner, reducing the administrative workload on contracting officers while increasing the quality of the outcome,” the solicitation states.

When selecting services over the simplified acquisition threshold, contracting officers are required to consider vendors’ past performance. CPARS is the central system federal officials use to collect and share contractor and vendor past performance information. But according to the solicitation, anecdotal evidence indicates that contracting officers face challenges trying to use the data for past performance evaluations, due primarily to the “volume of records and the inability to rapidly identify relevant reviews.”

Keep reading this article at: https://www.nextgov.com/emerging-tech/2019/08/dhs-wants-ai-improve-contract-performance-assessment-reporting-system/159418/

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2019 NDAA analysis: Enhancing IDIQs and other provisions

Over the past several months, this blog has analyzed several key provisions of the Fiscal Year 2019 National Defense Authorization Act (NDAA) that impact government contractors. This post briefly summarizes a variety of other government contracts-related provisions of the FY 2019 NDAA that we have not yet discussed, including several that reflect a congressional intent to enhance the use of multiple-award, indefinite-delivery/indefinite-quantity (IDIQ) contracts and encourage commercial item contracting, several that concern subcontracting and supply-chain considerations, and assorted other issues.

Awarding IDIQ Contracts Without Considering Price to Increase Order-Level Competition.

Section 876 provides a limited exception to the general requirement in 41 U.S.C. § 3306 that agencies must include cost or price to the government as an evaluation factor in evaluating proposals. The exception applies to task-order contracts (i.e., IDIQ contracts) for services that are priced on the basis of hourly rates. Specifically, agencies need not consider price as an evaluation factor for such contracts if:

  1. the agency will award a base contract to every “qualifying offeror”—meaning a responsible source whose proposal conforms to solicitation requirements, meets all technical requirements, and is otherwise eligible for award; and
  2. the agency will consider cost or price to the government in competitions for individual task orders.

This provision applies to non-defense agencies. Defense agencies had previously been granted a similar exception in the FY 2017 NDAA. See 10 U.S.C. § 2305(a)(3)(C).

Congress’s goal, as evidenced by the title to section 876, is “Increasing Competition at the Task Order Level.” By awarding base IDIQ contracts to all compliant proposals, without discriminating between them based on price, agencies are likely to have more contract-holders available to compete for specific work at the task-order level. Use of this mechanism should reduce an important barrier to entry to many potential competitors—not holding the necessary IDIQ contract to compete for work solicited under task order solicitations—and, by increasing competition, could result in lower pricing and better technical offerings at the task order level.

 

 

Keep reading article at: http://www.mondaq.com/article.asp?articleid=810088

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Could ‘microconsulting’ disrupt government contracting?

I have never been a fan of contractor bashing.

I believe there is nothing wrong with making a profit. I do not believe that contractors typically spend their days dreaming up ways to cheat the government. Indeed, I even believe that many contractor employees and managers believe deeply in the missions of organizations they work for, and get satisfaction from helping citizens and society through their organizations’ efforts — an observation I discussed a while back in a blog based on an informal conversation at a Coalition for Government Procurement event.

Having said that, I was a strong advocate even when in government 20 years ago for bringing more suppliers who primarily sold to the commercial marketplace into government contracting. Indeed, at a strategic level one of the main thrusts of the procurement reform efforts of the 1990s was to reduce barriers to entry for commercial firms created by government procurement rules — both in terms of the complexity of the process and some government oversight requirements that were burdensome or expensive for contractors to comply with.

Keep reading this post at: https://fcw.com/blogs/lectern/2017/07/kelman-microconsulting.aspx 

 

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Changes coming to SAM.gov

The General Services Administration (GSA) is planning to test a new version of the System for Award Management (SAM.gov).

This means that plans GSA made as far back as 2001 may be realized sometime in 2018.

At present, SAM.gov is the federal database where vendors register to do business with the government.   When it went live in mid-2012, SAM was introduced as portal where, over time, several different government databases would be consolidated.  Federal Agency Registration (FedReg), the Online Representations and Certifications Application (ORCA), and the Excluded Parties List System (EPLS) were among the systems to be first consolidated under the SAM umbrella.

The 2012 introduction of SAM initially was delayed and, once launched, many problems were encountered by vendors and government agencies alike.  Since then, SAM experienced a data breach in 2013, cost overruns, accessibility issues, and periodic interface difficulties with SBA’s small business database.

GSA now plans to resume work on the original vision for SAM: the consolidation of as many as 10 websites.

A new test site, at beta.sam.gov, reportedly is to launch between July 1 and Sept. 30, 2017.

The objective of the consolidated web site is to reduce the federal contracting burden on contractors and government officials alike by creating a single place to access a range of data, including contractor registration information, contract award data on prime contractors and subcontractors, and information about companies excluded from pursuing government work.

Eventually, the functions of 10 existing sites — including SAM.gov, the Federal Procurement Data System (fpds.gov); Federal Business Opportunities (fbo.gov), the Federal Funding Accountability and Transparency Act Subaward Reporting System (fsrs.gov), and the Federal Awardee Performance and Integrity Information System (fapiis.gov) — will become a part of the SAM beta site.  Once testing is completed, all of the added functionality will become a part of a new SAM.gov site.  The sites that are merged into SAM.gov then will be retired.

Improvements, such as search features, will continue to be made to existing sites as the new site is being tested, GSA says.

 

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