Link: GAO Opinion
Agency: Department of the Air Force
Disposition: Protest denied.
General Counsel P.C. Highlight:
GAO denied the protest of Global Defense Solutions, LP based on the award of a contract to SOF Associates, JV, under a request for proposals (RFP), issued by the Department of the Air Force, Warner Robins Air Logistics Center, for advisory and assistance services (A&AS).
The RFP was issued as a service-disabled veteran-owned small business set-aside, and contemplated the award of an indefinite-delivery/indefinite-quantity contract for services supporting aircraft weapon systems for various aircraft models. Offerors were required to provide knowledgeable and experienced personnel for logistics management; engineering support; and configuration management. Award would be made after considering past performance and price. The past performance factor required completed past performance questionnaires for recent and relevant contracts and recent was defined to be active or completed contracts performed within three years prior to the issuance of the RFP. The RFP also provided various specific definitions of relevance.
Global Defense’s proposal was eliminated from competition after the agency found that the protester failed to demonstrate relevant past performance. Out of the four past performance references submitted by the protester, the agency found the first was not relevant in size, scope, and complexity. The remaining three were not relevant in magnitude and did not involve the same services as required. Global Defense objected to the determinations made regarding its past performance.
GAO found that the record supported the reasonableness of the agency’s evaluation. GAO found that the contracts were of a much smaller value and that Global Defense failed to demonstrate that the agency was unreasonable in concluding that the references were not of similar scope and complexity.