An offeror was not entitled to a high past performance score merely because it proposed a subcontracting relationship with the incumbent prime contractor.
In a recent bid protest decision, the Government Accountability Office (GAO) held that an agency had properly assigned the offeror a mere “Satisfactory” past performance score, despite a subcontracting relationship with the incumbent, because the prospective prime contractor had not sufficiently demonstrated its own relevant past performance.
The GAO’s decision in TechTrend, Inc., B-412009, B-412009.2 involved a Forest Service solicitation for human resources information technology and contract advisory and assistance services. The solicitation was issued as an 8(a) set-aside.
The solicitation stated that award would be made on a best value basis, considering three factors: technical capability, past performance, and price. With respect to the past performance factor, the solicitation provided that the Forest Service would assess the past performance of the prime offeror and its proposed subcontractors. However, the solicitation stated that the experience of the prime offeror was more important than the experience of subcontractors.
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