Offeror's Past Performance Experience Not Precise Enough to Be Relevant

Friday, August 03, 2018 3:52 am
August 2018 - Volume 40 Number 8

Denied: Evaluation

Matter of: Tantara Corporation 2018 U.S. Comp. Gen. Lexis 159 (Comp. Gen. May 23, 2018)

The Comptroller General denied a bid protest because the offeror failed to prove the evaluation and award process was unduly restrictive in its past performance requirements. 

In March 2015, the U.S. Army Corps of Engineers (the Corps) issued a request for proposals (RFP) for an indefinite-delivery, indefinite-quantity (IDIQ) multiple-award task order contract (MATOC) to provide various environmental services. The MATOC was comprised of six IDIQ contracts with a total capacity of $230 million that were set aside to be awarded on a competitive basis to economically disadvantaged small business participants in the Small Business Administration’s 8(a) business development program. Tantara Corporation (Tantara) submitted one of the 25 proposals the Corps received.

Tantara didn’t win the contract, and challenged the Corps’ evaluation of its proposal under the technical approach and past performance factors. Tantara argued that the best-value tradeoff determination was flawed. The Comptroller General disagreed and denied Tantara’s protest.

Definition of technical excellence was a wish list

Tantara be[..]