The bar for proving a CPAR is “arbitrary and capricious” remains high. A CPAR is inherently subjective, and overcoming the presumption of regularity is difficult.

Forget art. What if agencies used non-fungible tokens for reporting contractor performance? Forget art. ... From CPARS to Tokenized Performance Ratings.

In fact, once a CPAR is issued, a contractor only has 14 days to provide a response. See 48 CFR § 42.1503(d). This is a hard deadline because if the contractor fails to respond, ...