Contractor Performance: Actions Taken to Improve Reporting of Past Performance Information

What GAO Found

The Office of Federal Procurement Policy's (OFPP) strategy to improve the reporting of past performance information relies on increased oversight and enhancements to guidance and acquisition regulations. Since 2009, OFPP has taken several actions to increase the number and quality of past performance submissions available to source selection officials, including:

• emphasizing reporting requirements through memos to agency officials;

• assessing and reporting on the level of compliance and quality of evaluations;

• directing the development of a compliance tracking tool;

• setting performance targets for certain agencies;

• directing the consolidation of systems for entering past performance information; and

• developing government-wide past performance guidance.

To implement provisions of the act, OFPP and the Federal Acquisition Regulatory Council (FAR Council) worked to enhance requirements for assigning responsibility and accountability; implement standards for complete evaluations; and ensure submissions are consistent with award fee evaluations. Recently, OFPP and the FAR Council revised the timelines for the contractor comment process in accordance with the 2013 statutory requirement.

Although agencies generally have improved their level of compliance with past performance reporting requirements, the rate of compliance varies widely by agency and most have not met OFPP targets. For the top 10 agencies, based on the number of contracts requiring an evaluation, the compliance rate ranged from 13 to 83 percent as of April 2014.

Rate of Compliance with Past Performance Reporting Requirement as of April 2013 and April 2014 for Top 10 Agencies Based on Number of Evaluations Due

Source: Past Performance Information Retrieval System | GAO-14-707

According to an OFPP official, some agencies placed greater emphasis on documenting contractor performance, but workforce shortages and work priorities may hinder better compliance. The official said that OFPP plans to continue its oversight and provide additional training and guidance.

Why GAO Did This Study

Having complete, timely, and accurate information on contractor performance allows officials responsible for awarding new federal contracts to make informed decisions. Agencies generally are required to document contractor performance on contracts or orders exceeding certain dollar thresholds.

Section 853 of the National Defense Authorization Act for Fiscal Year 2013 required the development of a strategy to ensure that timely, accurate, and complete information on contractor performance is included in past performance databases. The act also required a change to the timeframes allowed for contractors to provide comments, rebuttals, or additional information pertaining to past performance information. The act required GAO to report on the actions taken in response to these requirements. For this report, GAO identified (1) the OFPP strategy to improve the number and quality of contractor past performance evaluations and implement provisions of the act, and (2) changes in the compliance rates for required performance evaluations from April 2013 to April 2014 for selected agencies. GAO reviewed OFPP memos and reports, government-wide guidance, and recent changes to the Federal Acquisition Regulation and interviewed an OFPP official. GAO also reviewed past performance reporting compliance data for 2013 and 2014.

GAO is not making any recommendations. OFPP concurred with GAO's findings.

For more information, contact William T. Woods at (202) 512-4841 or woodsw@gao.gov.