Comment on FR Doc # 2012-21973

Document ID: FAR-2012-0009-0003
Document Type: Public Submission
Agency: Federal Acquisition Regulation
Received Date: September 07 2012, at 09:22 AM Eastern Daylight Time
Date Posted: November 9 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: September 6 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: November 5 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 8110b95a
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The rule should read that “Agencies shall prepare all past performance reports electronically in CPARS at http://www.cpars.gov/. All completed reports in CPARS transmit to the Past Performance Information Retrieval System (PPIRS) at http://www.ppirs.gov for viewing by Government source selection officials.” With this change the burden to federal clients of filling out many past performance evaluations each formatted and scored differently many without proper instructions for each and every solicitation is removed. The Past Performance Evaluation results would be more consistent allowing for impartiality and accountability by agency evaluators which currently is non-existent. It would also make it so that solicitations are based on clearly identified fact encouraging procurement offices to make best value to the government decisions. My small 8(a) company was unfairly evaluated in multiple 100% 8(a) set-aside solicitations because the DOL/OASAM procurement office blocked the COTR from putting our past performance evaluations in the CPARS and PPIRS. OASAM was then able to use other sources, in our case unauthorized hearsay and gossip from a source that had no basis or position to evaluate our past performance to undermine our past performance evaluation scores. The DOL/OASAM office handles the procurement for almost all of the 29 sub-agencies within the Department of Labor (DOL). OASAM's award decisions are rarely based on the best value to the government. See DOL/OIG Audits from 2005 - 2012. OASAM has been violating FAR using its loopholes and "losing procurement documentation" to help cover up its malfeasance for many years with impunity. The OIG no longer has the power to make them accountable for these many FAR violation. Perhaps strengthening the FAR may help but there still needs to be an government agency that can make all government procurement offices accountable to FAR and for making best value to the government award decisions.

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