Staying ahead of proliferating reporting databases.

• Author: Goodwin, David P.
• Position: Ethics Corner

A contractor's past performance record is much like an individual's credit score--it has immense effect on one's financial success, there is a high potential for inaccurate information and the only effective defense is constant diligence.

The government's newest online clearinghouse for past performance information is called the Federal Awardee Performance and Integrity Information System (PAPIIS). Its records cover past adverse actions, suspension or debarment entries from the Excluded Parties Listing System (EPLS), information on administrative settlements and other contractor-reported data.

Past contract performance evaluations are not publicly accessible--through FAPIIS or otherwise,--but they are accessible to government contracting officials through the Contractor Performance Assessment Reporting System (CPARS) and the Past Performance Information Retrieval System (PPIRS).

In the last year there has been a trend toward making past performance information more readily available, both inside and outside government. In January, a final rule was issued that makes many types of past performance information--other than past performance reviews--available through FAPIIS. Notably, the rule also gives contractors only seven calendar days in which to review and object to a proposed release of information through the system.

On July 18, the Office of Federal Procurement Policy invited public comment on possible changes increasing contracting officers' access to information regarding all locations of all corporate affiliates of a contractor in FAPIIS. The office also sought comment on different mechanisms for obtaining this information, including both increased reporting obligations and third-party business intelligence vendors.

These changes mean that contractors must take great care to stay on top of past and ongoing performance evaluations. One crucial aspect of this effort is the management of due dates and time-lines. For example, once a preliminary CPAR evaluation is received from an assessing official, a contractor's designated representative has only 30 days to review, comment on and return the evaluation. Should the representative not do so, he or she may lose an important opportunity to comment on and seek changes to the evaluation. This task is further complicated by...