Past performance information is a key indicator of an offeror’s ability to successfully perform a contract and is required to be considered by agencies when making most types of contract awards. Many small businesses, however, get their entrance into government contracting through subcontracts to prime contractors. These first-tier small business subcontractors often have a difficult time providing verifiable past performance because they are outside of the Contractor Performance Assessment Reporting System (CPARS) process that provides that information for prime contractors.
The good news for first-tier small business subcontractors is that the 2017 National Defense Authorization Act (NDAA) amended the Small Business Act to require the Small Business Administration (SBA) to implement a pilot program to establish past performance ratings for small business subcontractors. Under this program, a small business concern without a past performance rating as a prime contractor in the Past Performance Information Retrieval System (PPIRS) may request a past performance rating in CPARS if the small business is a first-tier subcontractor under a covered Federal Government contract requiring a subcontracting plan in accordance with FAR 19.702(a). Ratings of subcontractor performance can also be requested on subcontracts that exceed the simplified acquisition threshold, or subcontracts for architecture-engineering services valued at $35,000 or more as provided in FAR 42.1502.
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See the proposed rules and how to submit comments by June 19, 2018 at: https://www.federalregister.gov/documents/2018/04/20/2018-08330/information-collection-subcontractor-past-performance-pilot-program
