Best practices have emerged since a requirement was added to the Federal Acquisition Regulation in 2009 to report and use past performance information on contractors, Office of Federal Procurement Policy director Daniel Gordon told a commission on wartime contracting.
The hearing was convened to examine the use of past performance information and the suspension and debarment process. Gordon noted the following best practices:
-DoD has developed a compliance-tracking tool (to check that past performance has been entered into the database) that will soon be rolled out to civilian agencies to assist them with their compliance and oversight efforts;
-DHS has developed a quality checklist to improve the information included in past performance evaluation reports;
-The senior procurement executive at NASA receives a monthly delinquency report to monitor and manage compliance;
-The EPA holds an annual past performance – stand-down day where its SPE discusses the status of compliance efforts with EPA program officials;
-The Department of Education has issued guidance delineating the roles and responsibilities of stakeholders in the contractor assessment process;
-The Department of Energy has issued guidance that includes examples of desirable and inappropriate past performance language; and,
-The Department of Health and Human Services, an early adopter in the use of past performance information, has issued internal guidance for its operating divisions that shares past performance practices that have been used successfully by other agencies.