CPARS Explained: How Past Performance Ratings Work and How to Protect Yours

Which contracts get a CPARS evaluation

FAR Subpart 42.15 requires evaluations for contracts and orders above the simplified acquisition threshold, with different floors for some categories: construction contracts above a higher dollar level, and architect-engineer contracts above a lower one. Interim evaluations are required at least annually on longer contracts, and a final evaluation at completion. Below the thresholds an evaluation is optional, so a strong small order may leave no record at all, which is why asking for one can be worth it.

What is rated

Each evaluation scores the areas that apply to the contract: technical quality, schedule, cost control, management, small business subcontracting where a plan was required, and regulatory compliance. Each area gets one of five ratings.

• Exceptional. Performance exceeded many requirements to the government's benefit, with no significant problems. Rare, and it must be justified in the narrative.
• Very Good. Exceeded some requirements, minor problems fully resolved.
• Satisfactory. Met requirements; problems, if any, were minor and handled. This is the normal rating for good work.
• Marginal. Did not meet some requirements; corrective action was needed. A marginal rating follows you.
• Unsatisfactory. Did not meet most requirements, or recovery was not underway. This one can end a firm's federal business.

The narrative matters as much as the rating. Evaluators must explain their ratings with specifics, and a source selection team reads the words, not just the labels.

The fourteen-day window

When the assessing official completes an evaluation, the contractor's designated representative is notified and has 14 calendar days to review it and add comments. If you comment, the evaluation goes back to the assessing official, who may revise it or keep it, and you can request review one level above the contracting officer. After the window, the evaluation is finalized with your comments, if any, attached. Miss the window and the government's version stands alone.

Two practical consequences: keep your CPARS representative current in the system, since notices go to that person and nobody else, and never let a rating you disagree with go uncommented. A calm, factual rebuttal with dates and deliverables is part of the record every future evaluator sees.

How evaluations are used

Under FAR 15.305 the source selection team assesses recency, relevance and quality of past performance, and CPARS is its primary source. Evaluators can also consider information from other sources, including their own experience. A firm with no relevant record cannot be rated favorably or unfavorably on past performance: FAR 15.305(a)(2)(iv) requires a neutral evaluation, which is how new contractors get to compete at all. Neutral does not beat a Very Good, so building a record early, even on small orders, is the strategy.

Protecting the rating during performance

1. Ask the contracting officer's representative for feedback monthly and write it down. A rating should never surprise you.
2. Document every deliverable, every schedule change the government requested, and every problem you raised early. This is the material for a rebuttal, and for the narrative you would like the evaluator to write.
3. Request an interim evaluation on a multi-year contract when performance is strong; a good interim rating is a good rating in your record.
4. Resolve problems in writing and confirm the resolution in writing. The difference between Satisfactory and Marginal is often whether the fix was recorded.
5. At close-out, offer the contracting officer a one-page summary of outcomes against the statement of work. Evaluators are busy; many will use it.

What subcontractors and new firms can do

Subcontractors do not receive CPARS evaluations; the prime does. A sub can still build past performance through past performance questionnaires that solicitations allow, through the prime's written references, and by moving to small prime awards where an evaluation will be written. Two satisfactory ratings on small primes are worth more in a source selection than years of invisible subcontract work.