Past Performance: Building It When You Have None

Past performance evaluation creates a structural chicken-and-egg problem for any company trying to enter federal work. Contracting officers rely on past performance because it is one of the more reliable predictors of successful contract execution, and FAR 15.304 lists it as a factor that must be evaluated in nearly every source selection. A company with no federal prime contracts has, by definition, no federal past performance record to offer. The FAR anticipates this problem directly, and there are established, legitimate routes through it.

How past performance is actually evaluated

Evaluators typically look at three things: relevance, recency, and quality. Relevance asks whether the referenced contract resembles the scope, complexity, and dollar magnitude of the work being competed. Recency asks whether the work happened recently enough to say something meaningful about current capability. Quality is the actual performance record, drawn from CPARS ratings, past performance questionnaires submitted by references, and sometimes direct knowledge held by government evaluators who worked with the company before.

A glowing quality rating on a contract with no relevance to the work being competed carries far less weight than a solid, unremarkable rating on directly comparable work. Companies assembling a past performance volume should prioritize relevance first and polish second.

CPARS and how it follows a company

The Contractor Performance Assessment Reporting System is the government's system of record for documenting how a contractor performed against cost, schedule, quality, management, and small business subcontracting objectives on a given contract. Ratings typically run from exceptional down to unsatisfactory. A contractor is given an opportunity to review and comment on a CPARS report before it becomes final, and disagreements can be escalated, but the record, once final, is visible to contracting officers government-wide and stays attached to the company for years. Treating CPARS as a routine paperwork exercise rather than a strategic record is a common and costly mistake.

The FAR's answer to having no record

FAR 15.305(a)(2)(iv) states plainly that an offeror without a record of relevant past performance, or for whom information is not available, may not be evaluated favorably or unfavorably on past performance, and must instead receive a neutral rating. This provision exists precisely so that new entrants are not automatically locked out of federal competition. A neutral rating does not help a proposal, but it does not sink it either, which means the technical and price volumes have to do more of the persuasive work.

Four legitimate routes to a relevant record

1. Subcontracting under an experienced prime

Performing as a subcontractor on a federal contract, particularly a NASA contract, builds a documentable record of relevant work even though your company was not the prime. Some primes will provide a letter of reference or a completed past performance questionnaire describing your subcontracted scope, which can be cited in a future proposal. Chapter 13covers how to structure these relationships and what belongs in the teaming agreement that makes this kind of reference possible.

2. Corporate experience and predecessor entities

Where permitted by the solicitation, an offeror can sometimes present relevant experience performed by a parent company, an affiliate, or key personnel who performed similar work elsewhere, even absent an unbroken corporate lineage. Whether and how this is allowed is solicitation-specific and should be read carefully in Section L rather than assumed.

3. Commercial and state or local government work

Relevant past performance is not required to be federal. Commercial contracts and state or local government work of comparable scope and complexity can be submitted and evaluated, particularly where the underlying technical work, such as software development, engineering analysis, or fabrication, closely resembles what NASA is buying.

4. SBIR and STTR contract performance

A completed Phase I or Phase II SBIR or STTR award is a genuine federal past performance record, evaluated under the same government-wide standards as any other federal contract.Chapter 14 covers how these awards function as both funded research and a legitimate on-ramp to a company's first citable federal performance history.

Building the record deliberately

Companies that treat past performance as something that accumulates by accident tend to end up with a thin, poorly documented history even after years of contract work. Companies that treat it as a deliverable, requesting a completed questionnaire or reference letter at the close of every relevant engagement and tracking CPARS ratings as they post, arrive at their next competition with a record they can actually use. The record is built one contract at a time, and the habit of documenting it should start with the very first one.