The protester said the agency evaluated past performance too stringently, requiring references identical to the requirement instead of merely similar. GAO disagreed. The protester’s references—while adjacent to the requirement—weren’t in the zone of similarity.
Prosperitus Solutions, LLC, B-421461, B-421461.2
- Solicitation Required Medical Administrative Support – The solicitation stated past performance references needed to be similar to the requirement. The requirement was for medical administrative support. This included researching professional requirements, recording physician orders, providing information to patients, and using medical databases.
- Protester’s References Didn’t Involve Administrative Support – The protester’s past contracts were medical-adjacent. They involved sterilizing surgical instruments, warehousing medical equipment, and providing nurses. But this past work did not involve medical administration. The contracts were not similar to the requirement.
The protester is represented by John L. Holtz, Gregory P. Weber, Stephanie L. Ellis, Nicole D. Pottroff, and Shane J. McCall of Koprince McCall Pottroff, LLC. The awardee is represented by Ryan C. Bradel, Camille Chambers, and Chelsea A. Padgett of Ward & Barry, PLLC. The agency is represented by Julia Hatch, Jason R. Smith, and Jessica F. Volsey of the Defense Health Agency. GAO attorneys Christine Milne and Tania Calhoun participated in the decision.
–Case summary by Craig LaChance, Senior Editor
