Data & Analytics|September 17, 2026|14 min read

How to Evaluate Teaming Partners Before Capture: A Vetting Scorecard

Vet teaming partners with accessible evidence: SAM.gov exclusions, capacity checks informed by FAR 9.104-1, federal award records, workshare math, and conflict screening.

Sarah Thornton|Head of Proposal Strategy

Suppose a partner's capability deck lists agency customers, contract vehicles, and experience in NAICS 541512. A USAspending search could show that the available prime-award record covers different work [8]. The capture team should reconcile the claim with contract numbers and partner-provided documents before drafting an exclusivity clause.

Evaluating a teaming partner before capture means completing six documented checks and recording the evidence: eligibility and exclusion status in SAM.gov [12], an internal capacity screen informed by the FAR 9.104-1 standards for prospective contractors [3], contract footprint checked in FPDS and USAspending [8], workshare feasibility under the limitations on subcontracting at 13 CFR 125.6 [5] and FAR 52.219-14 [11], cyber posture under the CMMC program at 32 CFR part 170 [13] and DFARS 252.204-7012 flow-down [14], and organizational conflict screening under FAR Subpart 9.5.

Relationship maps and reference calls belong alongside accessible records such as SAM.gov, FPDS, award documents, and a signed teaming agreement. CPARS evaluations have restricted access under FAR 42.1503; a prospective prime cannot independently search a partner's evaluations [7]. FAR Subpart 9.6 treats contractor team arrangements as an accepted way to complement capabilities [1]. What follows is the six-domain scorecard, the workshare stress test, the cyber evidence list, and the past performance reconciliation routine to run before anyone signs.

The Capability Deck That Did Not Match the Contract Data

A gap between a partner's claim and federal award data can reflect differences in scope or terminology, so investigate before drawing a conclusion. A firm that supported an application modernization program as a third-tier subcontractor may genuinely call that "modernization experience." The buying activity may weigh it differently under the solicitation's past performance criteria [16].

Start every partner conversation with a verification pass, not a briefing. Pull the entity in SAM.gov and confirm registration status, the unique entity identifier, the representations and certifications, and any exclusion record [12]. FAR 9.405-2 governs subcontracting with excluded parties; an active exclusion requires a documented review of the applicable restrictions and any compelling-reason path before a commitment [4].

Then reconcile the story. Search the same entity in USAspending for NAICS and PSC codes, obligation ranges, customer agencies, and prime versus subaward posture [8]. If the partner claims a vehicle, ask which contract number and confirm it. If the partner claims an agency relationship, confirm whether the awards were prime or subordinate, because past performance instructions frequently distinguish the two.

Record each claim, supporting source, verification date, and open question before assigning the teammate work.

Six Evidence Domains Every Partner Has to Clear

Split partner diligence into six domains so nothing falls between capture and proposal management. Each domain has a primary authority, a source you can pull yourself, and a specific artifact that goes into the capture file.

Domain 1, eligibility. Active SAM.gov registration, unique entity identifier, current representations and certifications, and exclusion status [12]. FAR 9.405-2 makes an active exclusion a contracts escalation question [4].

Domain 2, capacity. FAR 9.104-1 lists the standards the contracting officer uses to determine whether a prospective contractor is responsible: financial resources, schedule capacity, performance and integrity records, organization, skills, and facilities [3]. A capture team can use those factors to screen a proposed subcontractor's ability to perform its assigned work. This internal screen does not replace the contracting officer's determination about the prospective prime.

Domain 3, footprint. Independent verification of vehicles, NAICS and PSC codes, obligation ranges, and customer agencies in FPDS and USAspending [8].

Domain 4, set-aside and workshare. Size and socioeconomic representations against the solicitation NAICS, plus a workshare model tested against 13 CFR 125.6 [5] and the clause at FAR 52.219-14 [11], and affiliation exposure under 13 CFR 121.103 [6].

Domain 5, cyber posture. Assessment status and scope under 32 CFR part 170 [13], flow-down obligations from DFARS 252.204-7012 [14], and control coverage mapped to the NIST SP 800-171 revision applicable to the solicitation [14]. Check the current CMMC rollout phase before treating an assessment as required [15].

Domain 6, conflicts. Disclosure of prior support to the buying activity and screening against FAR Subpart 9.5 categories.

DomainPrimary sourceEvidence artifactDisqualifying findingOwner
EligibilitySAM.gov entity record [12]Screenshot of registration status, UEI, exclusion search, datedActive exclusion with no compelling-reason path [4]Contracts lead
CapacityInternal screen informed by FAR 9.104-1 [3]Financial statement summary, staffing plan, integrity attestationNo credible evidence of schedule or financial capacityCapture manager
FootprintUSAspending and FPDS [8]Award list with contract numbers, NAICS, PSC, agency, obligationClaimed prime experience appears only as subawardCompetitive intel analyst
Workshare13 CFR 125.6 [5], FAR 52.219-14 [11], 13 CFR 121.103 [6]Percentage-of-effort model tied to WBS tasksSplit cannot meet the limitation without breaking the technical approachPricing plus capture
Cyber posture32 CFR part 170 [13], DFARS 252.204-7012 [14], current CMMC rollout guidance [15]Applicable assessment status, scope boundary, SSP summary, POA&M listPartner cannot document controls or an assessment required by the solicitationSecurity or compliance lead
ConflictsFAR Subpart 9.5 disclosuresSigned disclosure of prior agency support and data holdingsImpaired objectivity that cannot be neutralized or mitigatedContracts plus legal

Build the Partner Scorecard Before You Build the Relationship Map

Score each domain three ways: Verified, Open Question, or Fails Verification. Nothing else. "Probably fine" is how unpriced risk enters a bid.

Every Open Question needs a named owner and a next action with a date. That is the entire discipline. The same logic that makes an automated compliance matrix useful applies to partner diligence: a requirement without an owner and a next action is not tracked, it is remembered, and memory does not survive a proposal schedule.

Then build the relationship map on top of the evidence. Each row should carry the entity name and UEI, the workshare percentage, the capability claim in the partner's own words, the document that supports it, the verification date, and one sentence explaining the match. When your pink team asks "how do we know this partner can run the tier-2 help desk," start with an award record and ask the partner for contract documents and customer references. Use a CPARS evaluation only if the partner can provide its own authorized copy [7].

Freshness rules that keep the scorecard honest

  • SAM.gov registration and exclusion status change without notice. Re-check within a week of submission and record the date [12].
  • Partner-provided performance evidence can change. Recheck the authorized records and references the partner supplies before submission [7].
  • Cyber assessment status expires or changes scope. Treat the assessment date and scope boundary as a dated fact, not a permanent attribute [13].
  • Size status shifts with revenue and employee counts. A small business partner in one fiscal year may not represent the same way in the next.
  • Key personnel commitments decay fastest. Reconfirm named staff availability at every proposal gate.

Weight the domains against how the loss would hurt. Eligibility and conflicts are pass or fail, because there is no pricing adjustment that fixes an excluded party or an unmitigated organizational conflict. Workshare and cyber posture are structural, so a failure means restructure rather than proceed. Footprint and responsibility are gradable, so a partial finding can be handled by narrowing scope.

An open question at signature becomes a risk you cannot price

If you sign a teaming agreement with exclusivity while a cyber assessment status or size representation is still unverified, you have transferred an unresolved compliance question into your bid at a fixed cost. By the time it surfaces, you may have written the technical approach around that partner's tasks. Ask counsel to define an off-ramp in the agreement, including the failed-verification trigger, notice process, allocation of costs already incurred, and any obligations that survive termination.

Workshare Math Belongs in Capture, Not the Post-Award Renegotiation

Model the subcontract payments before anyone writes scope language. Where the limitation applies, FAR 52.219-14 limits the amount paid to subcontractors that are not similarly situated. For services other than construction, the cap is 50 percent of the amount paid by the government for contract performance; supplies and construction have different bases and caps [11]. Check the solicitation, contract type, each subcontractor's similarly situated status, and any work that subcontractor further subcontracts under 13 CFR 125.6 [5]. A raw labor-share percentage cannot establish compliance.

Run the ostensible-subcontractor questions from 13 CFR 121.103 as a hostile reviewer would [6]. Who manages the contract? Whose facilities host the work? Who supplies the program manager and the key personnel? Is the small prime dependent on the large partner for the primary and vital requirements? A structure that answers "the partner" to most of those questions creates affiliation exposure regardless of how the paperwork reads.

Then choose the structure deliberately. A prime and subcontractor team under FAR Subpart 9.6 [1] is faster to stand up and easier to unwind. An SBA-approved mentor-protégé joint venture has additional written requirements: 13 CFR 125.8(b)(2) prescribes specific contents including designation of the managing venturer, an employee responsible for performance, profit distribution, bank account arrangements, recordkeeping, and how the venturers will meet performance-of-work requirements [9]. Those are not drafting suggestions. For an SBA-approved mentor-protégé joint venture, the team should document those terms before relying on the joint venture structure.

Three practical rules from running both structures:

  1. Confirm mentor-protege approval before you rely on it. The affiliation exception for mentor-protege pairs operates under 13 CFR 125.9 and applies to approved relationships [10]. Ask for the approval letter and put a copy in the size representation file.
  2. Register the joint venture entity in SAM.gov early. An incomplete registration blocks submission, and registration is not a same-day task [12].
  3. Put percentages in the agreement, not in a side email. If the workshare is a range, define who decides within the range and on what date.

Set-Aside Alignment and NAICS Coverage: What the Codes Actually Prove

Match the solicitation NAICS and size standard against the partner's SAM.gov representations, not against the partner's self-description [12]. A firm can describe itself as an IT services company and still represent under a code with a size standard that does not fit the pursuit.

NAICS and PSC history proves something narrower than most capture teams assume. It proves that the government coded work to that entity under that code. It does not prove the entity performed the technical scope you care about, and it does not distinguish a $40,000 delivery order from a five-year program. Read the obligation ranges and the periods of performance, not just the code list [8].

Worked example: the 541512 pursuit with a 541519 partner

Consider a hypothetical systems design task order under NAICS 541512. A prospective partner's deck claims design experience, but the accessible award records could show mostly operations and maintenance work [8]. The capture team should request the relevant contract documents and customer references. If the partner has an authorized copy of its own CPARS evaluation, it can offer that as additional evidence; the prime cannot retrieve it independently [7].

One possible response in that hypothetical is to narrow the partner's role to sustainment and transition support, keep design and architecture with the prime, and add a second teammate for the security engineering gap. The proposal would cite each teammate only for tasks it will actually perform, consistent with the solicitation's past performance criteria under FAR 15.305.

When coverage is thin, you have three recovery moves and no fourth: narrow the partner's scope to what the evidence supports, add a second teammate for the uncovered capability, or bring the requirement in-house and price the hiring risk. Choosing among them is a pursuit gate decision, and it belongs in the same review where you make your go/no-go decision, not in a proposal-week scramble.

Cyber Posture as a Gating Test, Not a Post-Award Cleanup

Ask one question first: will this partner's scope involve covered defense information or operationally critical support? If yes, determine which safeguarding, assessment, reporting, and subcontract flow-down requirements apply before award. The CMMC program is codified at 32 CFR part 170, which establishes the program's assessment levels and requirements [13]. DFARS 252.204-7012 requires safeguarding of covered defense information, adequate security, cyber incident reporting, and flow-down for subcontracts involving covered defense information or operationally critical support [14].

Collect evidence, not assurances. Four artifacts, dated:

  • Assessment status and level, including who performed it and when, mapped to the program requirements at 32 CFR part 170 [13].
  • Scope boundary description, identifying which systems and enclaves are in scope and which are not.
  • System security plan summary for the in-scope environment.
  • Open POA&M items with owners and target dates.

Then compare the partner's stated controls to the NIST SP 800-171 revision in effect when the solicitation was issued, or the version authorized by the contracting officer, as DFARS 252.204-7012 specifies [14]. A July 2026 defense update suspended CMMC Phase II requirements while retaining Phase I self-assessments and the Revision 2 interim standard [15]. Check the actual solicitation before setting an assessment gate. A partner with a strong enclave and a weak general corporate network can still hold a workshare if the CUI never leaves the enclave. That is a scoping decision you can only make with the boundary documentation in hand, held to the same standard as the CMMC documentation assessors accept from you.

Extend the same discipline one layer down. Supply chain risk practices in NIST guidance apply to your partner's own subcontractors and any shared-service or offshore dependencies, which is where surprises usually live. The subcontractor supply chain documentation you already assemble for prohibited-source screening covers most of it. Write the DFARS 252.204-7012 flow-down, incident notification timelines, media preservation, and investigation access into the teaming agreement itself [14]. Then set a re-verification checkpoint two weeks before submission, because a change in assessment status after the technical volume is written forces either a workshare change or a partner substitution.

Making Teammate Past Performance and Conflict Screening Survive Review

Read the past performance instructions before you collect anything. Note whose experience may be submitted, how many citations are allowed, and the relevance and recency limits. Half the wasted effort in teammate past performance comes from collecting citations the evaluation criteria will not permit the agency to consider.

FAR 15.305 addresses past performance evaluation in negotiated acquisitions and supports consideration of subcontractors that will perform major or critical aspects of the requirement. The operative words are "will perform." Every teammate citation needs a line in your technical volume naming the tasks, the key personnel, and the percentage of effort that partner owns. A citation with no matching workshare reads as a paper relationship, and evaluators recognize it.

Reconcile before you commit. Start with accessible SAM.gov, USAspending and FPDS records, contract documents the partner can provide, and customer references. FAR 42.1503 restricts access to CPARS evaluations [7]. You may ask the evaluated contractor to provide an authorized copy of its own relevant evaluation, but do not assume a capture team can retrieve it independently. Compare any evidence with the citation and retire claims it does not support. Store the verified source and date in a reusable past performance content library.

Conflict screening runs in parallel and follows a different logic. FAR Subpart 9.5 addresses organizational and consultant conflicts of interest, and the three common fact patterns need different remedies:

  • Biased ground rules: the partner helped write the specification, statement of work, or supporting analysis. Mitigation is usually structural, meaning the partner cannot compete on that scope.
  • Impaired objectivity: the partner would evaluate or oversee its own work or a competitor's. Mitigation often requires removing the conflicting task from the partner's workshare.
  • Unequal access to information: the partner holds nonpublic agency or competitor information. Firewalls, personnel segregation, and named data holdings can work if documented before proposal development.

When the facts are ambiguous, ask the contracting officer through the solicitation's questions process and preserve the written answer in the capture file. For example, if a proposed teammate helped develop requirements for the buying activity, disclose the work and ask whether the proposed role creates a conflict. Use the response to adjust the workshare before the technical outline is locked.

Frequently Asked Questions

Can we team with a partner that has an exclusion record?

An active exclusion calls for a contracts review before a teaming commitment. FAR 9.405-2 restricts covered subcontracts with excluded parties, but it also provides a compelling-reason path and distinguishes consent, subcontract value, commercially available off-the-shelf items, and notice requirements [4]. Check SAM.gov [12], document the proposed subcontract and applicable conditions, and escalate to the contracts lead and contracting officer before deciding whether the exception can apply.

Does a teaming agreement need workshare percentages?

Recording a proposed workshare is a useful capture control, but these provisions do not require percentages in every teaming agreement. First check the solicitation, the applicable small-business program rules, and whether FAR 52.219-14 is included [5][11]. Where a limitation applies, model amounts paid to subcontractors that are not similarly situated and document the assumptions before committing to a technical approach. A joint venture may also have program-specific agreement requirements [9].

What does FAR Subpart 9.6 let a contractor team actually do?

FAR Subpart 9.6 recognizes contractor team arrangements as an accepted way for companies to complement each other's capabilities on a specific acquisition [1]. FAR 9.601 defines the arrangement as either a partnership or joint venture, or a prime contractor and its subcontractors agreeing to act as a team [2]. The contracting officer applies FAR 9.104-1 to the prospective contractor, normally the prime. The prime can use the same factors as an internal screen of proposed subcontractors' capacity for assigned work [3].

Will evaluators credit a subcontractor's past performance?

Only if the solicitation permits it and the citation maps to work the subcontractor will actually perform. FAR 15.305 supports consideration of subcontractors performing major or critical aspects of the requirement. Confirm the citation with accessible award data, partner-provided contract documents, and customer references. An authorized copy of the evaluated contractor's own CPARS record can supplement that evidence [7].

When does affiliation become a size risk?

When the control questions in 13 CFR 121.103 start answering in the large partner's favor on management, facilities, key personnel, and dependence for the primary and vital requirements [6]. Mentor-protege relief applies to SBA-approved pairs under 13 CFR 125.9, so verify the approval rather than assume it [10].

Does a partner need a cyber assessment before we can put it on the team?

It depends on what the partner's workshare touches. If the partner will receive or generate covered defense information, DFARS 252.204-7012 requires safeguarding, incident reporting, and flow-down to that subcontractor [14]. Ask for the applicable assessment status, scope boundary, and open POA&M items, then compare in-scope controls to the NIST SP 800-171 revision required by the solicitation or authorized by the contracting officer [14]. Confirm the current CMMC phase and level for the award before treating a certification as mandatory [13][15].

Do joint ventures need specific written terms?

For an SBA-approved mentor-protégé joint venture, yes. 13 CFR 125.8(b)(2) prescribes contents including the managing venturer, the responsible employee, profit distribution, bank accounts, recordkeeping, and performance-of-work allocation [9].

Your Next Three Actions

  1. Review the off-ramp in your teaming agreement template this week. Have counsel define what happens if a domain fails verification before submission, including notice, proposal costs already incurred, and surviving obligations.
  2. Track one metric. Percentage of prospective partners with all six domains marked Verified before agreement signature. Start at whatever it is. Report it at every pipeline review.
  3. Run last quarter's signed teaming agreements through the scorecard retroactively. Log what was never verified. That list is your real risk register, and it will tell you which pursuits to reopen before the next proposal cycle.

Start with SAM.gov and USAspending, then record what the partner supplied and what remains open [8][12].

References