Past Performance for Software Companies: CPARS, References and Building a Record

2026-10-05#past-performance #small-business #saas #federal-market

By Philip Luca — Founder of GovExpress; prior domain experience at Bloomberg Government and GovWin IQ.

The first objection a software company hears when it starts selling to the federal government is some version of “you don’t have past performance.” Founders often take that to mean they can’t compete until someone else gives them a first contract. That isn’t quite how it works. Past performance is one evaluation factor among several. A company with no federal record is treated differently from a company with a bad one, and commercial work counts for more than most first-time sellers assume.

This guide covers what past performance is, where the government records it, how evaluators read it, and how a software company builds a record it can point to.

What “past performance” means in a federal evaluation

In a competitive federal procurement, the solicitation tells you how proposals will be evaluated. Price is almost always one factor. Technical approach usually is another. Past performance is the factor that asks a narrower question: how well has this company done similar work before?

Two words in that question carry most of the weight:

Relevance. How closely does the earlier work match this requirement in scope, size and complexity? A large, closely matched commercial deployment can be more relevant than a small, unrelated federal task order.
Recency. How recently was the work performed? Solicitations usually set a lookback window. Work older than that window may not be considered at all.

The solicitation’s evaluation section (often Section M) states how past performance is weighed against the other factors. The instructions section (often Section L) states what you must submit: how many references, in what format, and for what period. Read both before you choose which references to put forward.

Where the government records it: CPARS

When an agency awards a contract above certain thresholds, the Federal Acquisition Regulation (FAR subpart 42.15) requires it to evaluate the contractor’s performance. Those evaluations are recorded in the Contractor Performance Assessment Reporting System (CPARS).

A CPARS evaluation rates the contractor on areas such as quality, schedule, cost control, management and, where it applies, small-business subcontracting. Each area is rated on a five-point scale: Exceptional, Very Good, Satisfactory, Marginal or Unsatisfactory. Source selection officials on later procurements can read those evaluations.

Three things about CPARS matter to a new contractor:

You get to respond. Before an evaluation is finalized, the contractor is notified and can submit comments, including a rebuttal. The comment window is short, so make sure the right person at your company is registered to receive the notices.
It accumulates slowly. Evaluations are written per contract, at intervals and at completion. A first federal contract adds to your record over its performance period, not on the day it is awarded.
It isn’t the only source. Evaluators can also use references you provide, questionnaires sent to your customers, and other information they have. CPARS is the government’s record, not the whole of your record.

No record is neutral, not negative

The most useful rule for a new entrant is in FAR 15.305(a)(2)(iv). In a negotiated procurement, an offeror without a record of relevant past performance, or for whom information on past performance is not available, may not be evaluated favorably or unfavorably on past performance.

In practice that usually means a “neutral” or “unknown confidence” rating. Two cautions:

Neutral isn’t the same as competitive. If competitors have strong, relevant records, a neutral rating can still lose on a best-value tradeoff. The rule protects you from a penalty. It doesn’t give you credit.
The rule covers the absence of a record, not a thin one. If you submit references that turn out to be weak or barely relevant, they are evaluated as they are. Choose a few strong, relevant references over many weak ones.

Building a record before your first federal contract

You have more material than you think. FAR 15.305(a)(2)(iii) directs agencies to consider past performance information on predecessor companies, key personnel with relevant experience, and subcontractors that will perform major or critical aspects of the requirement, where that information is relevant. Together with commercial references, that gives a software company four ways in.

1. Commercial customers. Most solicitations accept commercial references and judge them on relevance like any other. A deployment for a large regulated enterprise, such as a bank, a hospital system or a utility, can be strongly relevant to a federal requirement of similar scale. Pick customers who will answer a questionnaire promptly, and brief them before an evaluator calls.

2. Subcontracting. Working as a subcontractor to an established prime builds federal experience before you hold a prime contract. Your performance is visible to the prime’s federal customer, and the prime can serve as a reference. Teaming with a prime that already holds a contract vehicle is also one of the faster routes to your first task order.

3. Key personnel. If the people who will run the work have done similar federal work at earlier employers, the solicitation may let you cite that experience. Read the instructions carefully: some solicitations credit key personnel experience under past performance, and others only under the technical or management factor.

4. Smaller and non-traditional awards. Purchases below the simplified acquisition threshold, SBIR and STTR awards and Other Transaction agreements are all ways a software company can get federal work with less weight placed on prior federal history. Each one, once performed, gives you a federal reference for the next.

Writing the past performance volume

When a solicitation asks for past performance references, the same habits help across agencies:

Map each reference to the requirement. For every reference, say plainly which parts of the current work it matches: the same type of software, a similar user count or data volume, the same security requirements. The evaluator shouldn’t have to infer relevance.
Use the government’s terms. If the solicitation describes the work in its own terms, use those terms when you describe your references.
Be specific about your role. If you were a subcontractor, say which parts of the work you performed. If you were the prime, say what you subcontracted.
Keep contacts current. A reference whose contact has left the customer, or who doesn’t answer a questionnaire, can leave that reference with no rating at all.
Don’t overstate. Evaluators can check what you claim against CPARS and against the references themselves. A claim that doesn’t match the record costs more than a modest claim that does.

What past performance doesn’t cover

Past performance answers “has this company done similar work well?” It doesn’t answer whether you are eligible to compete. Eligibility is decided by your SAM.gov registration, the NAICS code and size standard on the solicitation, any set-aside restriction, and any security authorization the work requires, such as FedRAMP for cloud services or CMMC for Department of War contracts involving controlled information.

It also doesn’t make a self-attested claim verified. A strong reference shows that a customer was satisfied. It doesn’t show that your compliance posture has been independently assessed, and buyers treat those as separate questions.

To see your company’s registration record alongside the other categories federal buyers review, score your company’s federal readiness.

The CMMC brief

What the Phase 2 suspension changed and what it did not — the obligations that still bind, the assessment path a contract puts you on, the scoping decision that drives the cost, and the sequence that fits inside a pipeline. Sourced from the primary record.