The protester argued that the agency unreasonably assessed the awardee's past performance because it was under a different NAICS code. This allegedly led to a flawed best-value determination. GAO determined that the agency's evaluation, which was based on the similarity of work performed, was reasonable, consistent with the solicitation, and adequately documented. Thus, it denied the protest.
SRM Group, LLC, GAO B-423695
- Background - The agency issued an RFP for lodging and transportation services for the National Guard’s Professional Education Center. The protester, SRM Group, LLC, contested the award to BryMak Associates, Inc.
- Evaluation of Past Performance - SRM Group contested the agency's assessment of the awardee's past performance, arguing that two references were irrelevant because they were under a different NAICS code. The agency determined relevancy based on the similarity of work performed rather than strict adherence to the NAICS classification. GAO found that the agency reasonably concluded that the references demonstrated work aligned with the RFP requirements.
- Best-Value Determination - The protester claimed the agency made a flawed best-value tradeoff based on the allegedly erroneous past performance evaluations. However, since GAO found the past performance assessments to be reasonable and aligned with the solicitation criteria, it also upheld the agency's best-value determination. GAO emphasized that a contracting agency has discretion in assessing and weighing past performance.
The protester is represented by Thomas K. David and Lewis Rhodes of Reston Law Group, LLP. The intervenor, BryMak & Associates, Inc., is represented by Richard W. Arnholt, Sylvia Yi, and Adam R. Briscoe of Bass Berry & Sims, PLC. The government is represented by Robert B. Neill, Major Joseph A. Seaton, Jr., and Lieutenant Colonel Anthony V. Lenze of the Department of the Army. GAO attorneys Suresh S. Boodram and Evan D. Wesser participated in the decision.
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