How do I address a 'past performance' requirement if my company has no direct federal contract history?

You address a past performance requirement without direct federal history by submitting your relevant commercial and state contract experience. The FAR allows agencies to consider past performance from commercial customers and state or local government when evaluating an offeror, as long as it is relevant to the solicitation's requirements. Make sure your submissions clearly describe the scope, size, and complexity of those projects, focusing on how they align with the federal RFP. You need to show you can do the work. State and local buys follow their own procurement codes, so those contracts are good examples of government work. If you win this, the Contractor Performance Assessment Reporting System (CPARS) will record your performance for future federal bids, as evaluations are required for contracts exceeding the simplified acquisition threshold annually and at completion. Building federal past performance as a subcontractor is a good strategy, but it is not necessary to bid as a prime. Just make sure your past work is relevant.