Understanding the Impact of Contracting Officer Changes on Your CPARS Ratings

When working with government contracts, your Contractor Performance Assessment Reporting System (CPARS) ratings can significantly influence your future opportunities. One factor that often goes unnoticed but can have a major effect on these ratings is a change in the Contracting Officer (CO) assigned to your contract. This post explores how such changes may impact your CPARS evaluations and offers practical advice to help you maintain strong performance records despite these transitions.

Contracting officer workspace with contract files and documents

What is CPARS and Why Does It Matter?

CPARS is a system used by federal agencies to document a contractor’s performance on government contracts. These evaluations cover areas such as quality, schedule adherence, cost control, and business relations. Agencies use CPARS ratings to make informed decisions about awarding future contracts, making these assessments critical for contractors aiming to build or maintain a strong reputation.

A high CPARS rating can open doors to new contracts and partnerships, while a poor rating can limit your chances and even trigger contract terminations. Understanding the factors that influence these ratings is essential for any contractor working with the government.

How Contracting Officer Changes Occur

Contracting Officers are government employees responsible for managing contracts from award through completion. They oversee compliance, resolve disputes, and evaluate contractor performance. Changes in COs can happen for several reasons:

• Change in the Adminstration

• Reassignments or promotions within the agency

• Retirement or departure from the agency

• Organizational restructuring

• Temporary absences or leaves

  
  

When a new CO takes over, they inherit the responsibility of assessing your contract performance, often with limited background knowledge about the contract’s history or previous interactions.

I was a contractor officer for 32 years prior to my retirement. I recently attended a virtual Health and Human Services Industry Day event, and it was disheartening to learn that 2/3 (about 1,000 people) of HHS contracting officers and contracting specialists were fired last year.  That is a staggering number of firings.

So how will the remaining contracting officers complete your CPARS? How will they know how you performed on the contract? Are they even going to process your CPARS in the near future? If they do, are they going rate all the CPARS factors Satisfactory because of their lack of knowledge of the work being performed?  There are many aspects of the reductions of staff that could have profound impact on your business.

Why Contracting Officer Changes Affect CPARS Ratings

Contracting Officer changes can impact CPARS ratings in several ways:

1. Differences in Evaluation Style

Each CO may have a unique approach to evaluating performance. Some may be more lenient, while others apply stricter standards. This variation can lead to inconsistencies in ratings, even if your performance remains steady.

2. Lack of Historical Context

A new CO might not be fully aware of past challenges or mitigating circumstances that affected your contract. Without this context, they may interpret issues more harshly or fail to recognize improvements made over time.

3. Communication Gaps

Transitions can cause communication breakdowns. If the outgoing CO does not provide a thorough handover, the incoming officer might miss critical information, leading to misunderstandings or incomplete assessments.

4. Changes in Priorities or Focus

Different COs may emphasize various aspects of contract performance. For example, one might prioritize schedule adherence, while another focuses on cost control. This shift can affect how your performance is rated.

Real-World Example

Consider a contractor working on a multi-year IT services contract. The original CO was familiar with the project’s complexities and recognized the contractor’s efforts to resolve unforeseen technical issues. When a new CO took over, they lacked this background and rated the contractor lower on quality and responsiveness. This rating impacted the contractor’s overall CPARS score, influencing their ability to win similar contracts later.

How to Manage the Impact of Contracting Officer Changes

While you cannot control CO assignments, you can take steps to minimize negative effects on your CPARS ratings. The following are steps you should take if your CO or COR change:

Learn who is your Agency Focal Point

Step 1: Considering these changes in personnel, the first step in this process is to make sure you know the contracting officer representative (COR) and contracting officer (CO) who is going to complete the Contractor Performance Assessment Report (CPAR) rating. With all the changes in personnel taking place in many agencies, finding out who has been assigned your contract/order and CPAR could be challenging.

When there is a change in agency personnel assigned to a contract/order that is going to receive a CPAR, an agency’s CPARS “Focal Point” is the person who will reassign the CPAR responsibility to new personnel. The Focal Point provides administrative oversight for CPARS within a contracting office. They ensure each contract’s performance evaluation record is routed to the right Contracting Officer and/or Reviewing Official (RO), or other required users. Contacting the focal point might be your best bet if you are unsure who the CPARS assessing officials (contracting officers) are going to be.

In addition, whenever you have questions regarding CPARS, the NAVSEA CPARS help desk has always been very responsive regarding any questions you may have regarding who is the Focal Point on your contract. The Focal Points are normally contracting personnel and your Focal Points may have also changed. Therefore, when in doubt, contact the NAVSEA help desk at  cpars-helpdesk@us.navy.mil. Reference your contract number and ask the question regarding who is your Focal Point.

Prepare a Self-Assessment

Step 2: The second step in this process is to prepare a self-assessment and submit it to the new contracting officer. This will be your key to mitigating their lack of understanding of the work being performed and how well you performed it. At CPARSradar, we recommend that contractors submit CPARS self-assessments to both your CO and COR on a semiannual basis. Submitting a self-assessment of your performance will not only educate the new personnel regarding your contract achievements, but it also assists the COR and CO in completing the CPAR.  

Meet with your new CO and COR

Step 3: Contact your new CO and/or COR and discuss your CPARS self-assessment with them. Schedule the meeting for ½ hour.  Their time is in short supply these days, particularly at the end of a fiscal year.  Review your CPARS self-assessment, factor by factor, rating by rating. Remember that to achieve an “Exceptional” Rating in any factor, you had to have two significant events that benefitted the Government.  To achieve a “Very Good” rating in any one factor, you had to have one significant event that benefitted the government.   Without documenting these significant events, your chances of receiving a rating above Satisfactory are limited.    

In this new world of change, including reductions in personnel, finding out who your new CPARS CO and COR can be challenging if you are unfamiliar with the CPARS processes. Learning who your focal point is and/or emailing the NAVSEA help desk will help you to determine who they are.      

In addition, you should take additional steps to receive the CPARS rating you deserve including:

Maintain Clear and Consistent Communication

• Document all interactions with the CO, including emails, meeting notes, and performance reports.

• Provide regular updates on contract progress, challenges, and resolutions.

• Introduce yourself proactively to a new CO and offer a summary of the contract history and key milestones.

  
  

Keep Detailed Records

• Maintain thorough records of your work, including deliverables, timelines, and any issues encountered.

• Use these records to support your performance claims during evaluations.

  
  

Request Feedback Early and Often

• Ask the CO for feedback throughout the contract period, not just at the end.

• Address concerns promptly to demonstrate responsiveness and commitment.

  
  

Build Relationships Beyond the CO

• Engage with other agency personnel involved in the contract, such as Contracting Officer Representatives (CORs) or technical monitors.

• Positive relationships with multiple stakeholders can provide additional perspectives that support your performance.

  
  

Taking these steps will ensure your company receives the CPARS rating it deserves.

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