Section 806 of the National Defense Authorization Act (NDAA) for Fiscal  Year 2012 required DOD to develop a strategy to ensure that evaluations  in past performance databases used for making source selection  decisions are complete, timely, and accurate.process was also to be revised so that contractor past performance  evaluations are posted to the databases used for source selection  decisions no more than 14 days after the performance information is  provided to the contractor. OFPP’s Past Performance Strategy Relies on Enhanced Oversight and Guidance and Revised Acquisition Regulations

OFPP’s strategy to improve past performance information and respond to  section 853 of the NDAA for Fiscal Year 2013 is to increase oversight of  contractor performance evaluations, develop government-wide past  performance guidance, and revise the FAR. Since 2009, OFPP has taken  a number of actions, in conjunction with other organizations, to improve  the amount and quality of past performance information available,  including emphasizing reporting requirements; assessing the level of  compliance and quality of evaluations; developing a compliance tracking  tool; setting agency performance targets; consolidating systems used to  enter past performance information; and developing government-wide  past performance guidance. In addition, OFPP worked with the FAR  Council to revise the FAR to implement provisions of the NDAAs for  Fiscal Years 2012 and 2013 related to assigning responsibility and  accountability; implementing standards for complete evaluations; and  ensuring submissions are consistent with award fee evaluations. Revisions by OFPP and the FAR Council to the timing of the contractor  comment process in accordance with the acts became effective in July  2014. In establishing these targets, OFPP reviewed the  compliance rates of agencies and found that the level of compliance  varied widely. The memo also highlighted  training opportunities for agencies’ acquisition workforces on  documenting contractor performance. Previously, contractors were allowed a minimum of  30 days to provide comments, rebuttals, or additional information. Compliance with the Reporting Requirement Varies Greatly by Agency

Although agencies have generally improved their level of compliance with  the reporting requirements over the last year, that rate varies greatly by  agency and most have not met the targets set by OFPP. As shown in  table 2, all of the top 10 agencies, based on number of contracts or  orders with an evaluation due in PPIRS, showed improvement in  reporting compliance from 2013 to 2014, but the compliance rate varied  from 13 percent to 83 percent as of April 2014. However, the official  noted that some agencies report workforce shortages, work priorities, and  time constraints as hindering better compliance. The OFPP official stated the office plans to continue its efforts to improve  past performance information and strengthen reporting compliance, by  taking the following actions:       collaborating with agency senior procurement executives to increase  management oversight and leadership; working with the FAR Council on the development of additional  regulatory guidance, as necessary, to standardize reporting practices  and improve agency consideration of past performance information; directing the Federal Acquisition Institute to develop useful training  aids to ensure agencies know how to consider performance  information prior to contract award and rate a contractor's  performance during the post-award process; overseeing the General Services Administration’s Integrated Award  Environment on system enhancements to ensure agencies have a  practical reporting tool with useful performance metrics to manage  and monitor not only reporting compliance but also quality reporting of  performance information; and  conducting outreach with internal and external stakeholders to garner  their thoughts on ways to improve past performance information  reporting.
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.

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.
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.