December 9, 2019

December 09, 2019

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R.I.P. PPIRS

First things first, I’m sorry about the title; I couldn’t resist. The longer, alternate title would have been “Rest In Peace – the Past Performance Information Retrieval System Sleeps with the Fishes.” But that doesn’t have the same kind of obscure, punchy, epitaph-type quality that I’m aiming for. So instead, I give you get a garbled mess of an acronym to remind us that the Past Performance Information Retrieval System (“PPIRS”) – the system once used by the U.S. Government to house the final performance assessments for government contractors – is no more. As far as epitaphs go, I think that most of us would agree that “R.I.P.” is just about what an acronym deserves.

Several years ago, my friend, Bruce Shirk, and I wrote a blog article about the federal government’s various “past performance” reporting and accountability systems for contractors, including the Contractor Performance Assessment Reporting System (“CPARS”) (dating back to around 2007), PPIRS (first introduced around 2009), and the Federal Performance and Integrity Information System (“FAPIIS”) (finalized in early-2010). We even drew a neat little picture to help demonstrate how data flowed through the various governmental systems. To this day, I still get comments from people about how helpful that blog article was to understand the alphabet-soup of overlapping federal reporting systems.

Well, seven years later, these systems continue to evolve, and PPIRS is officially no more – formally rolling into CPARS. And, in time, CPARS will be no more, eventually rolling into the multi-functional, highly integrated, federal System for Award Management (“SAM”), available at SAM.gov (and currently available in a semi-upgraded fashion at beta.SAM.gov). As Bob Dylan famously sang, “the times they are a-changin’.” As Sheryl Crow (less famously) sang, “I think a change … would do you good.”

In truth, PPIRS went away earlier this year, having been merged with the CPARS back in January 2019. But two recent rules in the Federal Register (84 Fed. Reg. 47865, September 10, 2019; and 84 Fed. Reg. 48507, September 13, 2019) punctuated the system’s “retirement” by revising the FAR (effective October 10) and DFARS to blot out any reference to the “PPIRS.”

The stated purpose for retiring PPIRS and folding the system into CPARS was to create “a single system” that “provides one location and one account to perform functions such as creating and editing performance and integrity records, changes to administering users, running reports, generating performance records, and viewing/managing performance records.” This has long made a lot of sense, as the two systems always had substantial overlap. The key difference was CPARS allowed contractors to comment on government-completed report cards, while PPIRS was purely internal to the government – a place to house those final government-completed report cards for display. Think of it like a curio cabinet in your grandparent’s home – it’s useful enough (I guess), and it’s helpful to display important and fragile things, but the curio cabinet is always the first thing to go when you start downsizing. And with the government hoping to consolidate everything into one system, the curio cabinet inevitably gets put out on the curb.

In time, the government intends to move all of its contractor information into a consolidated, one-stop-shop database at SAM.gov. Already, FedBizOpps.gov (fbo.gov, listing federal business opportunities and solicitation materials) is targeted for consolidation with SAM.gov by November 8, 2019. The Department of Labor’s wage determinations website (WDOL.gov) has also already been consolidated with beta.SAM.gov. Other resources such as FPDS.gov (federal procurement data system), FAPIIS.gov, and CPARS.gov will eventually be swallowed up by SAM. In the end, let’s hope that this consolidation leads to a better user experience, to better fidelity in the underlying data, and to greater efficiency in the procurement process (for government and industry alike).

For now, I wish PPIRS the best. My thoughts are with its family. It lived a good(?) and long(?) life, and it will be missed(?). May it rest in peace.

Copyright © 2019, Sheppard Mullin Richter & Hampton LLP.

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About this Author

David Gallacher, Attorney, litigation, administrative, and counseling issues
Associate

David Gallacher is a partner in the Government Contracts, Investigations & International Trade Practice Group in the firm's Washington, D.C. office.

Areas of Practice

Mr. Gallacher's professional experience involves a wide variety of litigation, administrative, and counseling issues related to federal procurement laws. His experience is extensive and includes complex litigation in federal court under the qui tam provisions of the False Claims Act, claims disputes before the Boards of Contract...

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