An agency reasonably considered the quantity of offerors’ relevant past performance, even though the solicitation only stated that the relevance and quality of past performance would be considered.
In a recent bid protest decision, the GAO held that the quantity of an offeror’s past performance is logically encompassed within a review of the quality of past performance, and need not be separately identified as an area of evaluation.
The GAO’s decision in A&D General Contracting, Inc., B-409296 (Feb. 24, 2014) involved an Army Corps of Engineers solicitation for services to support military construction and repair projects. The solicitation was issued as a small business set-aside. Evaluation was to follow a two-phase process. In the first phase, the Corps would consider past performance and technical approach. The most highly rated proposals would be invited to participate in phase two.
The solicitation stated that offerors’ past performance would be evaluated for relevance and quality. In this regard, offerors were instructed to provide up to five examples of their recent, relevant projects. The solicitation stated that the Corps would assign an overall performance confidence assessment rating based on the overall relevance and quality of the offeror’s past performance.
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