What You Need to Know About OFPP’s New Past Performance Memo

Future past sign postThe Office of Federal Procurement Policy (OFPP) dropped a memo July 10 with some new requirements for the acquisition workforce on the collection and use of contractor past performance information. In recent years, they’ve taken a number of steps to expand the governmentwide use of contractor past performance, from trying to make evaluations more uniform to seeking better reporting compliance. Now OFPP is adding some additional steps in gathering, evaluating, and sharing past performance.

The Federal Acquisition Regulation (FAR) doesn’t merely prescribe when and where source selection officials should find and use past performance information when evaluating offers (FAR 15.3), it provides the flexibility for Contracting Officers (COs) and other acquisition staff to seek out additional sources of information beyond what’s already contained in the Past Performance Information Retrieval System (PPIRS). And that’s exactly what OFPP is directing COs to do for designated high-risk, complex contract actions.

Specifically, the new outreach program asks that source selection officials complete the following activities (attachment 1 in the memo provides a full outline of the additional research and outreach steps required):

  1. Contact the CO, COR, or program manager from the contractor’s two largest, most recent federal contracts.
  2.  Review news articles, GAO or inspector general reports about a contractor’s business integrity and performance.
  3.  Use commercial performance databases outside of PPIRS that provide reviews and evaluations of companies.
  4.  Request offerors provide at least three to five references from recent contracts.
  5.  Request primes provide information on subs.

These activities, OFPP says, “are to be applied, at a minimum, [to] acquisitions (contracts or orders) for complex information technology (IT) development, systems, and services over $500,000, and other acquisitions identified by the agency as presenting a significant risk.” OFPP has previously laid out how to determine when a contract is high-risk.

The information gathered by these activities should be carefully evaluated as to its relevance and balanced with what’s already contained in PPIRS, the memo advises.  Documentation in the contract file must show how the performance information was used during source selection. It’s also important that solicitations contain these past performance methodologies, so contractors are aware of how their history of state, local, foreign, and commercial work will be collected and evaluated. Last, each agency’s designated past performance POC should be providing this information for contractors on high-risk contracts to senior agency leaders. 

The FAR clearly outlines how past performance evaluations should be prepared and maintained, and specific procedures exist for allowing contractors to comment on any adverse performance reviews that fall within the scope of PPIRS (FAR 42.15). For these the “extracurricular” outreach efforts, however, it is important for COs to remember to give contractors the opportunity to respond to any negative feedback that turns up as part of the enhanced past performance collection and evaluation.

Affordable Care Act’s Butterfly Effect

467136035In conversation, a friend often mentions the “Law of Unintended Consequences,” which refers to chain-event related outcomes that may not have been foreseen when an initiating action occurred. It is an extension of Chaos theory’s “Butterfly Effect” that suggests unforeseen linkages such as, “When a butterfly in California flaps its wings, weeks later, a typhoon hits Asia.” From a management perspective, this is “Systems Thinking,” the art and science of making reliable inferences about behavior by developing an increasingly deep understanding of underlying structure, as described by Barry Richmond in 1987 and perfected by Peter Senge beginning in the 1990s. Systems thinking is using the butterfly’s flap to predict and prepare for the typhoon.

I bring this up because the recently enacted Affordable Care Act (ACA) could be the “butterfly’s wing” that eventually causes a “typhoon” of workforce mobility.

Before the ACA, employees typically obtained health insurance by holding a full-time job with an employer who negotiated a health insurance plan and subsidized it as a benefit of employment. Many employees stayed with their organizations out of fear of loss of access to health insurance or due to continuity of care issues. This was especially true in the Government sector, where good healthcare coverage is a key benefit. Prior to the ACA, a break in insurance coverage could cause an individual to be denied new coverage or face very high premiums based on preexisting medical conditions. Leaving a Government job for no or lessor insurance was, simply put, a bad bet.

Now that ACA is experiencing greater acceptance as the law of the land and people are signing up for coverage through state or Federal exchanges, this potentially impacts the relationships between employers and employees. It may motivate Feds to move into the private sector or retire early with confidence that they will be able to obtain health coverage comparable to what they have now.

How has your organization prepared for this change? Have you considered the possible indirect consequences of the ACA on your organization?

  • More healthcare options may lead to higher turnover: If you had staff who didn’t want to change organizations under the previous health insurance environment, are they now feeling like they can make a move? Do you have a retention strategy for critical individuals? Is your recruitment capability ready to find people to replace them? Or will you have to recruit less experienced people and grow your own talent? Do you have  a robust enough succession plan to deal with these risks?
  • Higher turnover may lead to loss of institutional knowledge: Are you at risk as employees’ knowledge base walks out the door? Are your knowledge management practices defined and documented? Should you implement a shadowing or mentoring program to help with knowledge transfer? Are your employees skilled at collaboration and knowledge sharing or is this a skill they will need to develop? Do you need a knowledge management tool such as software?
  • Vacancies and the resultant loss of institutional knowledge may lead to suboptimal mission achievement: Is your organization ready to become a learning organization that embraces employee mobility while still driving high performance and achieving mission results?

Organizations can capitalize on a more mobile workforce resulting from ACA by taking a systems approach to workforce planning, including succession planning, recruiting strategies, and development strategies. Knowledge management is also critical to success. Although Human Resources often directs these programs, their success hinges on line managers and leadership’s ability to build buy-in and execute the plans in their organizations. Leaders need a successor for when they move up. Line managers need to know how to manage for retention.  And everyone needs to have a development plan in place to ensure departures don’t result in new skill gaps. The organization will benefit from the implications of the ACA by:

  • Leveraging a More Mobile Workforce: Recruiting employees who may have felt trapped in their existing organization and bringing them into your organization to upgrade your talent or fuel organizational growth. Are your networks robust enough to find and recruit these people? Is your culture flexible enough to accept outsiders and find a way to help them be productive from day one?
  • Speeding Phased Retirement and Part-timing: Enabling phased retirement and other part time work arrangements that can allow you to scale to meet your organization’s needs more fluidly. This addresses “brain drain” risks caused by retirement, attrition, or changes in family status.
  • Enabling Healthy Attrition: Encouraging existing employees who may have remained with your organization solely for the sake of their health insurance to move on to a better fit elsewhere.
  • Improving Knowledge Management: More efficient transfer of institutional knowledge will benefit the organization by freeing up time for innovation in driving mission results.

For employees, it frees up many who were afraid to fully retire or otherwise change their full-time employment arrangements to independent consulting or part-time work because of the implications related to obtaining health insurance. Now people will be able to pursue the kind of work and workload they desire and know that they can still sign up for health insurance coverage independent of their employment status.

2014-2015 should be interesting from a job change perspective. As the economy strengthens, unemployment dips, and the healthcare implications shake out, expect some of your colleagues to explore their options outside your organization, while others may want to join your team.

By anticipating this opportunity and thinking about how it affects the entire organization as a system, you can manage risks, upgrade your talent pool and position your organization to lead into the next decade.

Be Prepared for IT Leaders Retiring: Start Training Your High Potential Staff Now

Graph1The aging demographics of the Federal workforce has been apparent for years, and the latest set of data (March 2014) released by OPM show no improvement in the outlook. 

In the short term, the government has the benefit of the long years of service and experience of a seasoned workforce. Almost half of the IT workforce is now age 50 and above. Most of these workers are retirement eligible at age 55 or 56, so within a few years, as older workers retire and leave Federal service, so leaves that experience.

Funding in the Federal budget for training has been in short supply, and training needs will only increase as demand grows to replace the lost skills of the retirees. These younger workers who were born into the digital age also expect a much richer and dynamic learning experience. Training will have to be technically stimulating, professionally advancing, and personally entertaining. 

Management Concepts is rapidly expanding its extensive courseware into e-Learning offerings, which provide the scale, economy, and rich learning experiences to coincide with this change in Federal IT workforce demographics.  Look at this as a part of the larger, varied curriculum designed specifically for Federal IT workers.

Lesson from the VA: The Role of Culture in Optimizing Talent in the Federal Workforce

001-B340-2TRecently, failures of service at the Department of Veterans Affairs have been in the news.  Investigators have found that the problems at VA are not occasional occurrences but to quote the Washington Post, the VA suffers from “corrosive culture of employee discontent and management retaliation. “  

Unfortunately, organizational culture and workforce development continue to be particularly challenging for many Federal agencies. Federal agencies have always faced unique challenges in workforce development including competition in attracting and retaining talented employees.

To improve performance, the VA and other agencies facing similar challenges will need to develop and sustain high performance cultures.  To make this happen, Federal leaders must utilize benchmarked best practices.  

Recently, Management Concepts Press and my team at Penn State University have collaborated on a ground breaking book, Optimizing Talent in the Federal Workforce that analyzes some of these practices and how they can be best be used in a Federal environment.  My colleagues and I especially emphasize the importance of organizational culture:

Agencies are working to create a culture where employees want to be—and can be—as effective as possible in serving the public. A results-oriented performance culture system, as defined by OPM, is a system that “promotes a diverse, high-performing workforce by implementing and maintaining effective performance management systems and awards programs.” OPM identified six critical success factors for creating such a system (OPM, 2005):

1. Communication. Each agency should have a process for sharing information with all employees that allows employee feedback to involve employees in planning and executing the mission.

2. Performance appraisal. Each agency should have a process under which performance is reviewed and evaluated.

3. Awards. Each agency should recognize and reward individual or team accomplishment that contributes to meeting organizational goals or improves the efficiency, effectiveness, and economy of the government.

4. Pay for performance. Each agency should use pay-for-performance systems that link salary levels to an individual’s overall performance and contribution to the agency’s mission.

5. Diversity management. Each agency should maintain an environment characterized by inclusiveness of individual difference and responsiveness to the needs of diverse groups of employees.

6. Labor/management relations. Each agency should promote cooperation among employees, unions, and managers that enhances effectiveness and efficiency and improves working conditions.

Excerpted with permission from Optimizing Talent in the Federal Workforce by William J. Rothwell, Ph.D., SPHR, CPLP Fellow; Aileen G. Zaballero, M.S.,CPLP; Jong Gyu Park, MBA. © 2014 by Management Concepts Press. All rights reserved. www.managementconcepts.com

I’ll take Cognitive Analytics for $1000, Alex

Jeopardy! Power Players WeekOne of my fondest memories from my childhood is my family’s nightly ritual of gathering around the TV to watch Jeopardy! with Alex Trebek. I’m still a big fan of the show and when, in 2011, IBM”s Watson took on two Jeopardy champions I was captivated. Having worked on some early efforts to use Natural Language Parsing (NLP) and Latent Semantic Analysis (LSA), it was great to see how the technologies had advanced to allow querying of large sets of unstructured data using plain language queries.

Watson is just one, impressive, example of the growing field of cognitive computing and cognitive analytics.  Cognitive analytics refers to process of bringing together machine learning, natural language processing, and artificial intelligence to analyze large quantities on unstructured data in ways similar to those used by the human brain.

According to Deloitte’s Tech Trends 2014, “cognitive analytics relies on technology systems to generate hypotheses, drawing from a wide variety of potentially relevant information and connections,” and the emerging technology will be a growth area for many organizations in 2015.

In honor my favorite game show, I thought I’d provide a Jeopardy style list of ways Federal managers may, in the not too distant future, be able to use cognitive analytics to improve organization performance.

Answer: Natural language search agents.

Question: What tools can government agencies use to improve customer service in a resource constrained environment?

Apple’s Siri is arguably the most familiar version of an artificial intelligence-based natural language query engine, but corporations have been introducing more rudimentary versions of automated agents to support customer service for nearly a decade.

With enhanced language understanding, the introduction of machine learning that can improve the recommendations coming from search agents, and more access to information storage and processing power, opportunities are increasing to automate customer service functions. Cognitive analytic techniques will enable systems to interpret and connect disparate pieces of information to provide better answers and more resources in response to customer inquiries.

Automating elements of customer service processes (for both internal and external customers) helps support the agencies drive to maintain service levels with decreased resources. The key will be implementing the type of technology users are becoming accustomed to (e.g. Siri), while still allowing for easy access to customer service agents before users become frustrated with the technology experience.

Answer: Social media monitoring and sentiment analysis.

Question: How can a federal manager use cognitive analytics to understand trends in employee engagement and brand management?

In an increasingly connected world it is important for organizations to maintain awareness of how they are perceived on social media. Using analytic tools, agencies can monitor, aggregate and analyze trends in messaging on internal and external social media networks to understand how employees and the public view the organization. And emerging technologies for sentiment analysis offer a glimpse into the positive or negative views being communicated about the organization.

Answer: Better data aggregation, improved used of unstructured data, and faster data processing.

Question: How can cognitive analytics enable data driven decision making at my organization.

A recent survey by MarkLogic and GovLoop (here) suggests that many government agencies are struggling to realize the benefits of big data and advanced analytics for their organization. The merging of advanced technologies in the field of cognitive analytics will offer agencies a more streamlined, less technically challenging path to exploiting the volume of (structured and un-structured) data held across the enterprise to improve organizational performance.

By connecting previously disparate and often unstructured data sources to make predictions about organization performance and, ultimately, learning to improve those predictions over time, cognitive analytic systems can provide a leap ahead in an organization’s ability to make data driven decisions.


The rapid rise of big data, analytics, and the focus on data driven decision making has presented numerous challenges to Federal agencies.  Whether due to lagging technology infrastructure or critical skills gaps, many agencies have yet to realize the benefits of advanced analytic techniques. Exploring cognitive analytics may offer a near term solution to the analytics challenges facing Federal organizations.

Do you see a need for improved analytic capabilities in your organization? What challenges are you facing in improving your data driven decision making capabilities?