Link: GAO Decision
Protestor: LOGMET LLC
Agency: Department of the Air Force
Disposition: Protest Denied.
Protest that contracting agency improperly evaluated offeror’s past performance is denied where the record shows that the protester did not adequately demonstrate relevant performance in all required areas, and the agency’s evaluation was reasonable and consistent with the stated evaluation criteria.
General Counsel PC Highlight:
LOGMET LLC protested the award to B3 Solutions, LLC of a contract for logistics materiel control activity (LCMA) services at the Air Force Research Laboratory, Kirtland Air Force Base, New Mexico. The RFP contemplated award on a best value basis, considering past performance and price. Offerors were to provide up to five references, with up to five pages for each reference; references could be from federal agencies or commercial customers to demonstrate performance relevant to the RFP requirements. LOGMET’s past performance references contained only a one-paragraph listing of its responsibilities and functions for each reference. Based on the relevance and quality of its references, the agency assigned LOGMET a rating of satisfactory confidence.
LOGMET argued that the agency had improperly determined that LOGMET had not demonstrated relevant supply store and ITE asset management experience. The GAO found the agency’s evaluation of LOGMET’s past performance to be reasonable, confirming the agency’s determination that there was no discussion of these PWS requirements in any of LOGMET’s references. The GAO rejected LOGMET’s argument that, because LOGMET was the LCMA contractor at another Air Fore base, and because all Air Force LCMAs are organized and operated in the same, the agency should have understood that LOGMET therefore possessed all the required experience.
Offerors bear the burden of submitting well-written proposals that address all the terms of the RFP. Where the RFP provides page length limitations for various portions of a proposal, offerors must ensure that they do not go over the page restrictions or risk having critical aspects of their proposal ignored by the agency. However, offerors should utilize every page allowed to provide as much detail about their past performance as possible. Failure to thoroughly relate past performance to requirements of the RFP could result in a lower evaluation rating by the agency.