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Before a major federal award, identify the exact entity and business unit that will perform the work, then assess relevant performance evidence against the solicitation’s rules. CPARS is the government’s official source for past-performance information, but full evaluations are access-restricted; public SAM.gov checks can reveal exclusions and some responsibility information, not a complete performance history. A sound review therefore combines authorized records, public evidence, and a careful comparison of prior work with the proposed requirement.
Start with the solicitation and the proposed work
Get the solicitation and all amendments before evaluating a bidder. Record exactly how the agency says it will assess past performance; there is no universal scoring formula for every major award.
- Which past-performance factors and rating method apply?
- What counts as recent, and how many references or examples does the agency request?
- Will the agency consider work by proposed subcontractors, joint-venture members, or other team members?
- May the agency use sources beyond the references an offeror provides?
FAR 15.305 says the solicitation should describe the evaluation approach and give offerors an opportunity to identify similar federal, state, local, or private work. Use the solicitation—not assumptions about how agencies usually score proposals—as the standard for this award. FAR 15.305
Confirm which legal entity and team actually performed the work
Searches can mislead when a contractor’s parent, subsidiary, predecessor, affiliate, joint venture, or business division is confused with the offeror. Start with the bidder’s legal name and Unique Entity Identifier (UEI), then map its relationship to each organization named in a reference or award record.
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For every example, establish which entity and performing unit did the work, and whether that unit is part of the proposed team. Note any ownership or organizational changes since performance. FAR responsibility guidance addresses identified immediate owners, predecessors, and subsidiaries in specified circumstances; affiliate performance or integrity may also matter when it could adversely affect responsibility. These connections do not make every affiliate’s record automatically equivalent to the offeror’s own record. FAR 9.104-3
Use each records source for what it can establish
CPARS: authoritative, but not generally public
The Federal Acquisition Regulation states, “CPARS is the official source for past performance information.” Completed evaluations are treated as source-selection information, with access limited under the FAR. Contractors can view their own evaluations, but an outside reader should not expect to browse a company’s full CPARS narratives as public records. FAR 42.1501 FAR 3.104
SAM.gov: useful public checks, not performance narratives
Use the contractor’s SAM.gov Entity Information page to check available Exclusions and Responsibility/Qualification reports and related data services. Some entity information may require sign-in or be subject to access restrictions. Verify what a report covers and its date; these records can inform an integrity or responsibility review, but they do not replace CPARS evaluations. SAM.gov Entity Information
FAPIIS-related information and other evidence
Review available responsibility and integrity information, including reported terminations for default or cause. A termination entry is one consideration, not an automatic verdict about a bidder. Check its date, status, outcome, and whether later action changed the record.
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1Clear out junk files and repair common Windows errors2Fix the driver behind crashes, sound loss and screen glitches3Repair Windows errors before they cause bigger problemsWhere the solicitation permits and the material is accessible, use customer references, award documents, audit or inspection material, and public agency notices to corroborate what happened. Label each source accurately: a public notice or customer account is not an official CPARS evaluation. FAR guidance calls for considering a wide variety of sources in some acquisition settings, while the solicitation determines how the information is handled. FAR 15.305 FAR 9.104-6
Compare prior contracts with the requirement being awarded
Build a record for each relevant effort before drawing conclusions. Capture the customer, contract or order identifier, performance dates, awardee and actual performing unit, scope, verified value or scale, contract type, operating environment, and evidence source. Then compare each effort with the proposed award:
- Scope: Did the work involve comparable technical tasks or mission demands?
- Scale and complexity: Were delivery volume, coordination, and consequences of failure similar?
- Currency: How long ago was the work performed, and does it fall within the solicitation’s recency standard?
- Context: Were the customer, delivery setting, and operating conditions comparable?
- Team relevance: Will the same division, key personnel, or subcontractors perform the new work, and what roles did they have before?
- Organizational continuity: Has ownership or structure changed since the prior work?
These are practical comparison questions, not a universal statutory scoring rubric. FAR source-selection guidance directs evaluators to consider relevance and currency as well as the source and context of information and performance trends. FAR 15.305
Read the narrative behind each rating
FAR 42.1503 uses five adjectival ratings: exceptional, very good, satisfactory, marginal, and unsatisfactory. Each factor requires a supporting narrative. The definitions consider whether requirements were met, the customer benefit of performance beyond requirements, the extent of problems, and the effectiveness of corrective action. FAR 42.1503
A satisfactory rating means requirements were met; it is not a failure. The FAR cautions against lowering a rating merely because a contractor did not exceed the requirements. Look for the underlying facts and record:
- What requirement or deliverable was affected?
- How serious was the issue, and what impact did it have on the customer?
- Was it an isolated event or part of a repeated pattern?
- How promptly did the contractor respond, and did the corrective action work?
Weigh a problem in light of the contract and period involved. A smaller issue on closely analogous work may be more informative for this award than an unrelated success or failure. Separate documented findings from allegations, and distinguish a contractor’s response from an agency’s final evaluation.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Check adverse information and any response
For each adverse record, verify the underlying event and its current status. Do not treat a disputed allegation as an established finding, and include an available contractor response rather than presenting only one side.
Under FAR 42.1503, a contractor may comment or rebut within 14 calendar days after being notified that an evaluation is available for comment. A disagreement may receive review above the contracting officer, but the contracting agency makes the ultimate decision on the evaluation. FAR 42.1503
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Interpret the record’s time limits and gaps carefully
FAR 42.1503 specifies a three-year CPARS information window after completion of performance, extended to six years for construction and architect-engineer work, for the agency-use rule described there. These periods are not proof that every older record is irrelevant or that every in-window evaluation will be available to an outside reviewer; apply the solicitation and governing agency procedures. FAR 42.1503
A public search that finds no record does not establish that no CPARS evaluation exists or that the contractor has no adverse information. FAR responsibility rules also say an offeror generally cannot be found nonresponsible solely because it lacks relevant performance history. Treat missing material as an evidence limitation and consider other information the solicitation and applicable rules allow. Classified contracts and special access programs may be handled under separate agency procedures. FAR 9.104-1
Write a defensible assessment
For a high-stakes review, distinguish records directly examined from facts inferred or unavailable. Organize conclusions by the solicitation’s criteria and connect each conclusion to evidence about the performing entity, comparable work, and relevant time period. If CPARS or other restricted material is necessary, use authorized agency systems and follow the contracting office’s access and handling rules; a public SAM.gov check cannot fill that gap.
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