In federal contracting, your reputation is currency, and few tools can shape that reputation more than the Contractor Performance Assessment Reporting System (CPARS). CPARS evaluations don’t just sit in a file, they’re pulled directly into award decisions and can make or break your ability to win future work. How you respond and engage during the CPARS process can directly impact your pipeline of new business. Here are 6 effective tactics every government contractor needs to know—and should consider—when facing a CPARS evaluation.
- Understand the CPARS Process and the Clock You’re On
CPARS evaluations assess a contractor’s performance across key areas like: Quality, Schedule, Cost Control, Management, Regulatory Compliance, and Small Business Subcontracting (if applicable). The Assessing Official (AO)—typically a contracting officer, program manager, or similar official—completes the initial evaluation. Once it’s submitted in CPARS, here’s what happens:
- You’ll receive an email notification via CPARS.
- You have 60 calendar days total to submit your comments.
- BUT, after 14 calendar days, the evaluation becomes visible in the system for source selection with or without your input.
Translation: If you wait too long to engage, the government may begin using the CPARS against you in future evaluations, even if it’s inaccurate or incomplete.
- Read the Evaluation Carefully and Critically
Don’t just skim it. Before you respond, analyze:
- the overall rating (Exceptional, Very Good, Satisfactory, Marginal, Unsatisfactory);
- whether the narrative matches the numerical rating (one of the most common issues we see);
- any factual inaccuracies or omissions; and
- whether the evaluation complies with CPARS Guidance, including use of objective data, traceable metrics, and contractually relevant performance.
According to the CPARS Guidance, the narrative must support the rating and “should not be generic in nature.” If it’s vague, inconsistent, or based on inaccurate assumptions, you may have grounds to challenge.
- Respond Thoughtfully and Within the First 14 Days
To protect your record, you should submit your initial comments within the 14-day window. This ensures your side of the story is seen by future source selection officials. Use your response to:
- correct errors or mischaracterizations;
- provide documentation (emails, deliverables, QASP scores, etc.);[1]
- offer context (e.g., government-caused delays, scope changes); and
- reinforce where you met or exceeded expectations.
Pro Tip: Stay factual and professional. Avoid emotional or accusatory language. The tone of your response can affect how it’s received by the Reviewing Official and future evaluators. Your comments will be attached to the evaluation for future evaluation officials to review.
- Want to Challenge the Rating? Don’t “Concur”
If you click the “concur” box—even with comments—it may be interpreted as accepting the evaluation.
If you disagree with any part of the CPARS, select “non-concur.” This:
- flags the evaluation for review by a Reviewing Official (RO) and
- triggers the requirement for the RO to review and optionally provide supplemental comments.
Note: The RO does not change the AO’s original narrative, but their comments become part of the permanent record.
- Request a Meeting, But Act Fast
If the issues are significant, you can request a meeting with the contracting officer or program office. The CPARS Guidance states: “Meetings must be requested within seven (7) calendar days of receiving the CPAR.” Use the meeting to walk through your points and offer documentation that supports your position. While not mandatory, agencies can delay posting the CPAR in the system for other source selection officials to view while a dispute is being discussed. This is often referred to as “stopping publication of the CPAR.”
- If All Else Fails, You Have Options to Escalate
If your CPARS remains inaccurate after your response or meeting, and the evaluation is materially affecting your business, you can escalate further by:
- filing a claim under the Contract Disputes Act (CDA), asserting that the CPARS is not current, complete, or accurate.
- appealing any denial of your claim to the Board of Contract Appeals or U.S. Court of Federal Claims.
Final Thoughts
CPARS ratings follow you across agencies and future contracts. An inaccurate or unfair assessment, left unaddressed, can linger for years. By knowing your rights, responding within the right timelines, and backing up your record with facts, you can protect your performance history and your ability to compete.
If you need help crafting a strategic response or challenging an unfair CPAR, please contact Sam Finnerty or another member of PilieroMazza’s REAs, Claims, and Appeals and Government Contracts practice groups.
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If you’re seeking practical insights to gain a competitive edge by understanding the government’s compliance requirements, tune into PilieroMazza’s podcasts: GovCon Live!, Clocking in with PilieroMazza, and Ex Rel. Radio.
[1] CPARS does not support contractor uploaded attachments, so these documents may need to be paraphrased and cited within the response.
