FedSubK Feature: CPARS Secrets - Insider Tips for Maximizing Your Performance Ratings

Updated: Oct 1, 2024

Ever wonder why some contractors consistently win federal contracts while others struggle to get a single award? The secret often lies in past performance; how much they and their ratings. The system that collects and houses that information is the Contractor Performance Assessment Reporting System, or CPARS. Ratings in this system can make or break your chances of getting that Federal contract, but most contractors and consultants in GovCon don’t fully understand how to maximize it. I’m going to give you my insider tips that can elevate your game when it comes to your CPARS ratings – and your chances at contracting success.

First let’s cover some basics…

CPARS is the Government’s official source for past performance information (FAR 42.1501(b)). This system plays two roles:

(1) Collection of data about a contractor’s performance on a specific contract, and

(2) Provides source selection officials with valuable feedback from which to evaluate contractors for possible award of future contracts.

You can see why it’s something you might want to pay attention to, right?

CPARS ratings are required generally at least annually and at the time the work under a contract or order is completed (FAR 42.1502(a)). However, there are some thresholds that apply.

• Single-agency contracts and orders exceeding the Simplified Acquisition Threshold (SAT) (presently $250,000[1]), at the contract or order level, as determined by the Contracting Officer (CO/KO).
• Multiple-agency contracts and orders (i.e., GSA Multiple Award Schedule (MAS) contracts, Governmentwide Acquisition Contracts (GWACs), etc.) exceeding the SAT.
• Construction contracts exceeding the threshold in FAR 42.1502(e) (presently $750,000[2]).
• Construction contracts terminated for default regardless of dollar value.
• Architect-Engineer services contracts exceeding the threshold in FAR 42.1502(f) (presently $35,000[3]).
• Architect-Engineer services contract terminated for default regardless of dollar value.
• When a modification increases the total award amount over one of the thresholds above, a past performance evaluation is then required for that contract.

The CO/KO typically serves as the Assessing Official (AO) and oversees the process of the collection of past performance evaluation information from technical personnel, program managers, Contracting Officer’s Representatives (CORs), or sometimes, the quality assurance office and/or end user of the product or service. Of these officials providing input, the COR is typically assigned as the Assessing Official Representative (AOR) who enters the proposed performance evaluation and preliminary ratings into CPARS.

Evaluations are source selection information, and they must be treated accordingly and protected from release in accordance with FAR 3.104. CPARS evaluations are also considered pre-decisional in nature because they are used to support source selections on an ongoing basis. The only people that can view ratings, narratives, etc. for a specific contract are personnel with a need to know and the contractor who is the subject of the evaluation. In addition, evaluations are not releasable under the Freedom of Information Act, or FOIA. CPARS ratings are retained and used for source selection purposes for three (3) years following the completion of the contract or order; six (6) years for Architect-Engineer and Construction contracts. But those durations aren’t as short as they might seem, and ratings can hang around longer than you might think.

For example, let’s say we have a five-year contract for services, with an annual reporting requirement. That means the Government completes a past performance evaluation every twelve months. At the end of our five-year contract, there are five evaluations entered in CPARS. The clock doesn’t start ticking on the retention period in CPARS until the contract completion date. All five of those evaluations will remain in CPARS for three years beyond the contract end date, meaning the first evaluation is actually in the system approximately eight (8) years.

That’s not anything to sneeze at if you have issues on a long contract and those issues, even after they are overcome, will likely end up documented in the annual CPARS evaluation and could follow your business for nearly a decade! Evaluations are meant to serve to motivate good performance by Federal contractors.

Let’s look at the elements of a CPARS rating and talk about the rating criteria used. This is where my secrets come into play.

The evaluation factors that must be used, as a minimum, for each past performance assessment are found in FAR 42.1503(b)(2).

Secret #1: You Must Continually Self-Assess During Performance & DOCUMENT IT

As a CO/KO and COR who evaluated contractor performance on simple orders to highly complex contracts, the specific things we are assessing about your performance don’t differ much. I’m sharing my checklist with you that I used for YEARS when evaluating contractor performance under each factor.

Technical Quality of the Product or Service

• Did the product or service meet all technical specifications, standards, and performance requirements outlined in the contract? (FAR 42.1503)
• Was the work completed accurately and without the need for excessive corrections or rework?
• Did the contractor demonstrate the ability to identify and solve technical challenges or offer innovative solutions to improve performance or outcomes?
• Was the contractor consistent in delivering a high-quality product or service over the course of the contract?
• Was the work compliant with industry, safety, and environmental standards relevant to the contract?

Cost Control (not applicable to fixed pricing arrangements)

• Was the work completed within budget?
• Did the contractor demonstrate the ability to control costs without sacrificing quality or performance?
• Did the contractor avoid cost overruns? If not, were they justified, documented, and proactively communicated?
• How well did the contractor respond to budget or funding changes?
• Did the contractor conform with standard earned value management and cost control processes?

Schedule / Timeliness

• Were products or services delivered on time according to the contractual schedule?
• Did the contractor meet interim milestones (e.g., phased deliveries, project stages)?
• If delays occurred, did the contractor take proactive measures to mitigate the impact?
• How quickly and effectively did the contractor resolve delays?
• Did the contractor’s adherence (or failure) to the schedule affect the government’s mission or project outcomes?
• If there were modifications or change orders on the contract, how effectively did the contractor adjust to revised timelines?

Management and Business Relations

• How effectively did the contractor allocate and manage personnel, equipment, and other resources to meet the contract requirements?
• How effectively did the contractor manage key personnel assigned to the project, including their experience, qualifications, and how well they meet contract requirements?
• Did contractor responsiveness to staffing changes and its ability to replace personnel impact project performance?
• How did contractor management adjust resources when project demands changed, or unforeseen issues arose?
• How well did the contractor communicate effectively and regularly with the Contracting Officer and other government representatives?
• Were timely responses to inquiries, requests for information, or problem-solving efforts received from the contractor?
• Did the contractor engage proactively with the Government to identify and resolve issues before they escalated?
• How efficiently and effectively did the contractor identify and address challenges, whether technical, operational, or logistical?
• How willing and able was the contractor to implement corrective actions quickly and professionally?
• Did the contractor comply with legal and ethical standards, including honesty, integrity, and transparency in business dealings?
• To what degree did the contractor avoid conflicts of interest and adhere to ethical practices?

Small Business Subcontracting

• Did the contractor manage subcontractors efficiently and effectively, ensuring they meet performance expectations, deadlines, and contract requirements?
• Did the contractor perform oversight of subcontractor compliance with small business utilization goals, if applicable?
• Did the contractor make a good faith effort to comply with the terms of their small business subcontracting plan, if applicable?
• Was the contractor responsive to small business subcontractors in terms of resolving disputes or concerns raised during performance?
• Did the contractor have any untimely payments to small business subcontracts?

Other (as applicable)

• Were contractor reporting requirements completed timely?
• Did the contractor have any trafficking violations, tax delinquency, failure to report in accordance with contract terms and conditions, defective cost or pricing data, terminations, suspension and debarments, or failure to comply with limitations on subcontracting?
• Did the contractor adhere to Federal, state, and local laws or regulations that apply to the specific contract and work performed thereunder, including compliance with environmental, labor laws, and safety regulations?
• How well did the contractor adhere to required security protocols, including physical security, information security, and compliance with cybersecurity regulations (e.g., NIST standards) and protect any sensitive or classified information under the contract?
• Did the contractor incorporate sustainable practices, reduce environmental impact, and use energy-efficient technologies or processes (as applicable) during performance?

Early in my career, past performance evaluations were rated on an adjective scale similar to that in FAR Subpart 42.1503 today, but there were no standardized definitions for each. Agencies, not wanting to impact companies on future contract opportunities, would often default to the highest rating even though the contractor may have only met the requirements of the contract – and meeting the requirements is what they should be doing! COs/KOs could easily tell which agencies took a hardline approach when rating contractors more than others when viewed across the board. Unfortunately, none of that could be taken into consideration during proposal evaluations and many companies missed out on contract awards simply because of disparities between how agencies applied the adjective ratings. When Tables 42-1 and 42.2 were introduced into the FAR, this adjective rating scale suddenly became standardized across all agencies. It leveled the playing field again.

Secret #2: COs/KOs are Detail Oriented People But Sometimes Need Reminders

Now that FAR clearly outlines what the thresholds are to achieve each rating, you know what you need to do to get the ratings now, right? Eh, not so fast. I’ve heard contractors complain that they deserved an “Exceptional” and being very upset that they didn’t get one. Let’s take the definition of “Exceptional” from the FAR tables and use its corresponding note to break it apart.

“Performance meets contractual requirements…” This speaks for itself. Moving on...

“…and exceeds many…”

• What contractual requirements were capable of being exceeded?
• What does that look like under each evaluation factor?
• Is it possible for each evaluation factor?
• When you believe you have exceeded contractual requirements, you MUST—
  • Clearly document the requirement you exceeded and how, and
  • Make the Government aware of it DURING performance AS IT OCCURS.

“…to the Government’s benefit.”

• What type of contractual requirement, if exceeded, would benefit the Government?
• Can you quantify the benefit?
• Was it a technical, schedule, or cost benefit?
• Ask the Government if it feels it received a benefit and document the feedback received, when it was received, and from whom it was received.

“The contractual performance of the element or sub-element being evaluated was accomplished with few minor problems…”

• Did you encounter any problems in the Government’s eyes?
• Were they considered minor by the Government?
• If you aren’t sure, check in with the Contracting Officer’s Representative or other technical points of contact that oversee the work and ASK.
• Again, document the feedback.

“…for which corrective actions taken by the contractor…”

• If the Government directed corrective action, was it accomplished to their satisfaction and do you have a record of that (i.e., email, meeting minutes, etc.)?
• If you took corrective action, was it apparent to the Government?
• Did you document the actions taken for the record?

“…were highly effective.”

• Was corrective action highly effective in your eyes or the eyes of the Government?
• Did you get feedback from the Government on their perceived level of effectiveness? If not, ASK.

To justify an Exceptional rating, the Government must be able to identify MULTIPLE significant events and SUPPORT how they benefited the Government. If there is only a singular benefit, it must be of such a magnitude that it alone constitutes the Exceptional rating. Also, there can be NO significant weaknesses identified. Not as easy as you thought to get an Exceptional rating, is it?

A Very Good rating doesn’t require that much less than an Exceptional. The only difference is that only SOME contractual requirements were exceeded. Still not any easy get, eh?

Now you know in detail what COs/KOs and CORs are looking at AND must also be able to substantiate with SUPPORTING DOCUMENTATION.

If you are keeping that documentation up yourself through self-assessments, you can share it in the form of an “Annual Contractor Self-Assessment” with the CO/KO and COR before the next rating period and just in time to refresh their memory. Chances are that info will influence their ratings and they will rely, at least in part, on your supporting documentation. Good acquisition people don’t stay in one place long and you will likely provide the new person the best record of the performance during the rating period.

Secret #3: A Satisfactory Rating Means You’ve Performed All Contract Requirements.

The very definition of a Satisfactory rating is “Performance meeting contractual requirements” with only minor problems or major problems that the contractor recovered from without impact to the contract or order. There is no shame in a Satisfactory rating. There is no contractual requirement to perform over and above the contract requirements, terms, or conditions. FAR states, “A fundamental principle of assigning ratings is that contractors will not be evaluated with a rating lower than Satisfactory solely for not performing beyond the requirements of the contract/order.” You cannot receive less than Satisfactory when all contract requirements have been met. Conversely, a Satisfactory rating is all you're entitled to if you don't meet and exceed at least some or many contractual requirements to the benefit of the Government, like we broke down above.

Secret #4: ALWAYS Respond to Your CPARS Ratings

I cannot stress this enough so I’m saying it again. ALWAYS Respond to Your CPARS Ratings! If you want to make a CO/KO or COR really annoyed…ignore it. Then complain about it later. Then complain when you get the next rating and it’s not any different. And then don’t respond to that rating either.

(Getting the point here?)

Assign a Contractor Representative to monitor CPARS ratings and coordinate contractor comments on the evaluation received. The CO/KO will tell you when it has been released in CPARS for your review and the system will notify you by email. Now the clock starts ticking. You will have up to 14 calendar days from the date of notification of availability in the system to submit comments, rebutting statements, or additional information.

Don’t agree with a rating?

Respectfully state why you disagree AND substantiate your rebuttal with documentation and timelines. Don’t complain or get personal no matter what. Tell your side of the story and why you see it from a different perspective. But remember, the ultimate decision on the performance evaluation and ratings received is the decision of the contracting agency.

Once finalized, copies of the evaluation including your contractor response and review comments, if any, will be retained as part of the evaluation. Tell your side of the story! These evaluations are used to support future award decisions! COs/KOs will read that entire record including your take on events. You’ll get more in the long run by respectfully telling your story than making it a scathing account of drama on the project and throwing people (Government or subs) under the bus. Don’t create a future problem that doesn’t make a difference now!

Get an awesome rating and think, “Why should I provide a response to it?” That’s part of our next and last secret…

Secret #5: Don’t Leave It to the Government’s Imagination

There are two possibilities here.

The first is, you aced your past performance evaluation, and you don’t think you need to respond. Wrong. Want to impress the Government on that future opportunity? Acknowledge the rating and talk about the ways the project worked well within your contractor team and with the Government personnel. Maybe even highlight some lessons learned. You’ll make a great impression that way and it shows you appreciate the Government’s time to provide that good rating, even when you deserved it.

The other is that you didn’t get the evaluation you thought you should, and you are silent; no response is found in CPARS. What happens when you don’t tell your side of the story in CPARS when that next opportunity comes along? Now you've left it up to the Government’s imagination and interpretation. Is that really what you want to do – let there be any doubt that you did your best? Don’t be silent. Don’t let someone assume. Tell your story yourself. It does make a difference, even with the worst ratings it matters. Stuff happens. Even the Government can appreciate that when it's reasonable.

Now you've got my CPARS secrets from my days as a CO/KO and COR! Use them well. Did any surprise you? Let us know!

[1] See Federal Acquisition Regulation (FAR) 2.101 Definitions for the current threshold after 10/1/2025.

[2] See FAR 42.1502(e) for the current threshold after 10/1/2025.

[3] See FAR 42.1502(f) for the current threshold after 10/1/2025.

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