Monday, May 7, 2018

Jeepers Creepers, Fix CPARs and PPIRS!

I think you may read the headline and decide this is not a topic for you.  Too obscure, maybe, or nothing you care about.

But you need to care.  And if you can help fix it (e.g., if you are in government), well, please.

The Federal government in D.C. buys stuff.  Lots of stuff.  Every agency of government does that, and while we joke about NASA blasting five billion dollars worth of incredibly valuable items and a half dozen astronauts into space, all on a rocket "built by the lowest bidder", you get the idea.

We should expect that the businesses which sell those items are treated fairly and evaluated fairly; that business is not awarded to a company just because the owner is friends with a Senator, or a Clinton, or both.

But even absent politics, there needs to be common sense in the process, and that is frequently absent.  Let me try to explain a real failure in the system that is pervasive today.

This is not actually so much about the Feds, in this case the Defense Department, buying "things", so much as buying "hours."  In order to avoid hiring more government employees, whose salaries and benefits are huge taxpayer expenses and who are tough to fire or even lay off, the government contracts-out a lot of work to service contractors.  The contracts are to supply experts or specialists for a fixed period of time, after which the people -- and their costs -- may go away, or be renewed if the need is still there.

My profession is writing the proposals that contractors submit to compete for that kind of work.  So I am reasonably astute in the process of competing for Government contracts, and I see systemic problems that put at risk not only the Government's ability to get the best value, but the intrinsic fairness of the process.

Lesson #1 ... If you are trying to sell experts to the government, you need to show the Federal customer that you have done that kind of work before.  This is the "Past Performance" part of a proposal, and typically you will provide 4-5 descriptions of previous contracts you've done well at doing the same work.

Of course, the Government doesn't simply trust what you said you did.  So along with the 4-5 citations, you would be asked to have your past Federal customers fill out a form stating how wonderful you were on that assignment, and send it directly to your hoped-for customer.  That is called a "Past Performance Questionnaire" or PPQ.  Past customers absolutely hate having to fill out a PPQ, because (A) it involves writing (several pages), and (B) it involves writing the same stuff over and over in a slightly different way.

A contractor company can easily have to ask for the same PPQ as much as 20 times a year from a single customer, if the work is common and the company is doing a lot of bids.  That really can tick off their customer, and sometimes the 20th PPQ is not as flattering for just that reason.  A less-than-perfect PPQ can cost a company millions in business.

So ... someone finally saw the errors in that system, and a few years ago created a system, used in the Defense Department, called "PPIRS" (pronounced "PEE-pers"), the "Past Performance Information Retrieval System."

The principle was simple -- every year, Federal customers would write just one Contractor Performance Assessment Report ("CPAR") and file it in PPIRS.  Any Federal official conducting a procurement could download the CPARs for whatever past contract a company was citing in its proposal.  The past customer wouldn't even have to know about it, let alone be forced to do another PPQ.

It's 2018, and most Defense contracts of any real size have CPARs filed for them every year.  You'd think that would have solved the problem, right?  Sure.

I work about 30 different proposals a year.  Sometimes I am the lead for past performance, sometimes a different part, but in every case I am aware of the procurement's requirements for past performance.  And sadly, it's as if they never heard of PPIRS.  Jeepers, creepers!

In at least 3/4 of the proposals I do, there is still a requirement for contractors to ask for a PPQ from their past customers, whether or not there is a CPAR on file for that work.  Some requests ask that you make sure there is a CPAR on file and, bless them, only if there is not one do they ask for a PPQ.  But most of them just ask for a PPQ, meaning that you have to ask for one, from a ticked-off customer telling you "But I just did a full CPAR for that work!".  And it's not your fault.

I am working a proposal now for a client, a defense contractor.  Before the formal Request for Proposals came out, there was a period where we could ask questions of the Government, relating to draft documents the Government had released.  I asked one question to the effect that "Your draft Request asked for PPQs from five customers.  We ask that you remove that requirement for any past performance citation if there is a recent CPAR on file."

The actual question was longer than that; I actually made the point that the CPAR system was put in place to avoid ticking off customers by asking for PPQs.  But the government replied, tersely, "We will require PPQs for all citations."

Gee, thanks.

So I contacted my client company's program manager, who is running the contract that I want to use as a past performance reference.  I asked him if he would be willing to ask his customer for a PPQ.  "I can't", he answered.  "The program is almost over and they're evaluating proposals for the next phase of that work.  Until they award it, in December, the customer is refusing to do any PPQs."

Now, please note that even in an evaluation phase, there are zero Federal regulations preventing that customer from doing a PPQ in that period.  His customer is wrong.  And there are perfectly adequate CPARs in PPIRs for that work for several years; a PPQ shouldn't even be needed.

Suppose that work was an exact match for the work I'm bidding on, and my client had done a spectacular job, so it would be an ideal citation to use.  We could not use it, because (A) the Federal customer we're bidding to forces us to have a PPQ from every citation and won't use CPARs, and (B) the Federal customer for the work we are already doing has misinterpreted the law and thinks he can't do the PPQ.

Then suppose that my client is far and away the best to do the proposed work, but can't provide its best reference to prove our ability, and the Government ends up with a much lesser contractor because my client can't be shown to be as good as it is.  The taxpayer gets the lesser performance for our hard-earned and tax-confiscated dollar, all because of a very screwed-up system.

If you have a shred of influence; if you are a congressman or Senator, I beg you to help mandate that DoD contracting officers be far, far better trained and that acquisitions mandate that only CPARs be used for validation, and that PPQs may only be required if no CPAR is on file.

Because jeepers, creepers, that crap has to get fixed.

Copyright 2018 by Robert Sutton
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