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The Lectern:

The Lectern: I actually agree with the DOD IG!

By Steve Kelman
Published on March 4, 2008 - 11:29 AM

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I see that the Defense Department's IG has issued a report discussing shortcomings in how DOD records past performance report cards. Many of the reports are filled out late (the later the report, the poorer people's memories and the sooner the information on them becomes outdated). In 82 percent of the cases, the ratings did not include sufficient narrative to justify why the contractor had been given the rating they had.

Considering past performance when making awards is one of the most powerful tools the government has available to encourage good contractor performance. It is central to how the free market system works on behalf of customers: If I get a bad haircut, for example, I don't go back to the same barber the next time. Government folks should not see past performance evaluations as a drill or an unpleasant obligation, but as a tool for doing their jobs and supporting their agency's missions.

So the inspectot general is right to be concerned about problems here.

The government folks have an excuse, sort of. The formal past performance report cards suffer from a bad case of undifferentiation -- government folks hesitate to boast too loudly about truly outstanding performance and, even more so, honestly to criticize performance that is mediocre or worse. Part of the reason for that is the unfortunate FAR provision (which I confess I signed on to as the Offce of Federal Procurement Policy administrator, against my better judgment at the time) that allows contractors who don't like a rating to get the rating reviewed a level up the chain (rather than the more sensible approach of letting the rating stand, but allowing the contractor to put their version of events in the file). This discourages honesty by sending the message that if you say anything negative, you subject yourself to endless meetings and justifications with your boss.

I also think that for major contracts, contracting policy officers should develop a capability to do oral interviews of contracting and programming officials, guiding them through the past performance report cards and asking probing questions to draw out more and more differentiated information -- rather than just leaving filling out the forms to the offices themselves. Trained interviewers can do a better job eliciting good information.

Readers of this blog know I'm not a big IG fan. But when they're right, they're right.

I also seem to be in good company. The FCW online story about the report noted that Shay Assad, the Defense Department's senior procurement policy official, and Charlie Williams, senior procurement person in the Air Force, agreed with the IG's recommendation. Maybe they can work on developing an interviewing capability for doing report cards on major contracts.

I would like to hear reader recommendations for how government can strengthen the past performance system. Post a comment on this blog (registration required) or send an e-mail to letters@fcw.com (subject: IG) and the FCW staff will post it for you.

View Comments

This is definitely an area where we (govt Procurement) do a REALLY bad job. This is evident by the incredibly small amount of info available in PPIRS for some big-time vendors. Also, I cringe every time I see "excellent past performance rating" as an incentive in a Quality Assurance Plan for a contract. What happens when vendors realize that if they are lucky enough to actually receive a rating, it often doesn't get posted until years after the work is complete? I think an ebay/amazon-type past performance system for simplified procurements would be useful (you know- green, white, or red, short narrative, etc.), but every time I bring this up it seems to get shot down because "we can't even do the past performance reports that are required by the FAR" so how can we expect people to provide more information. I think it could work if it was integrated with a procurement system so the rating could be done at time of sale. Also consistent with Ebay/Amazon, sellers and BUYERS should be rated (call me crazy, but tell me why not?). How about a wiki approach to past performance for larger contracts?? It would go something like- Buyer provides brief rating and narrative, seller has opportunity to provide their narrative, future buyers can adjust/validate the ratings and revise/add to the narratives. I would like to say that some higher authority should regulate the info, but this wouldn't be in the true spirit of a wiki and I'd be making the same error in judgement that Dr. Kelman made when he signed off on the past performance FAR provision mentioned above. In his defense, he did leave us with enough flexibility to implement the Ebay/Amazon system mentioned above. You make excellent points Dr. Kelman and I'm fast becoming a regular reader of your blogs.

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