There's Always a Better Way, O Ye Federal Contracting Officers

A while back, one of the decorative shutters in the front of our house was blown down in a particularly violent storm and broke into two pieces when it landed. Since the shutters' color had changed over 15 years, I had to hire "a guy" to come to the house and replace eight sets of shutters with new ones.

He did a fine job. Since he does that job pretty often and it isn't very complex, that's not a surprise, of course. But imagine for a moment that it was your house, and you had the guy do that work. Then imagine that, oh, 5-6 times a week, different people call you and ask you to write a three-page description of the work the guy did, and how well he did it, and how long he took. Imagine that you had to write that up in a different format each and every time, because each person that called had his or her own way of doing it.

In the private-sector world you and I live in, we would tell the second person who called to go pound salt in his ear, with elevated threat levels to each subsequent caller, and then finally change phone numbers.

In the lovely world of Federal contracting, however, this is routine. To give you a sense of what I'm talking about, thousands upon thousands of contracts are let by the USA for all manner of services that are better done and cheaper if contracted out. For each of those contracts, except when a corrupt offical does its little sole-source trick to its friends (coughObamacarecomputerglitchcough), there is a formal request for proposal (RFP) issued, and different companies present proposals to do the work.

The number of companies varies -- I've seen as many as 100 bids submitted -- but I'd say the most common number is between five and twelve proposals per request. Almost all the RFPs ask for what we call in the trade "Past Performance." For that, the bidder provides a two or three-page writeup for (typically) 3-5 jobs it has done, that are recent and of the same kind of work (the "references").

In a large percentage of cases, this is supplemented by something called the "Past Performance Questionnaire" or PPQ. Very simply, when the bidder receives the RFP, it must send the PPQ to each of the references, which are generally other Federal offices. The recipient must complete the PPQ describing the work quality, and return it straight to the customer no later than the due date of the proposal.

Do the math. If there are ten bidders then, on average, someone in each of 40 different Federal offices is setting aside his or her important work, to write up the details on what a current or recent contractor is doing or has done, and provide an lengthy opinion on the quality of their work.

And that's for one -- count it, one RFP. A large contractor doing, say, $5 or $6 billion a year, is doing literally hundreds of proposals a year. The number of relevant references is finite, so the same ones are going to get used. And used. And used. As a contractor, I have to grit my teeth before contacting a customer and asking politely if she will, for the 23rd time since October, fill out a PPQ to say how great we are.

There are a lot of really good contracting officers out there who would prefer never to do a PPQ again but do them anyway because it's their job and their contractor has helped them a lot. So why, why must each RFP have a different specification as to whether the contractor is any good? If they were good when a PPQ was filled out yesterday, chances are they will be good tomorrow when the next one comes out.

Ironically, there is a Federal Contractor Performance Assessment Reporting System (CPARS) and a Past Performance Information Retrieval System (PPIRS). The Government has actually created a medium in which customers annually review their contractors, creating the reports via CPARS and storing them in a retrieval system (PPIRS).

Would it be too much to ask for the Government to use it as the only source of this data? Could they implement a deadline (not a White House red line, please) -- let's say 31 December 2015 -- after which PPQs are by law no longer to be used, and every Past Performance request in an RFP must be done through PPIRS? We could even require customers to fill out a CPARS entry semiannually or even quarterly -- surely they'd prefer that to 177 ad hoc requests per year, right? Surely the Government would prefer that its employees do their actual job, paid for by the taxpayers, rather than spending hours filling out PPQs.

OK, my dream. Perhaps my Congressman can consider this.

Copyright 2017, 2015 by Robert Sutton