Wednesday, July 20, 2016

Nonsensical Past Performance Rating

The Army issued a "best-value" solicitation to purchase some practice bombs under a five-year ID/IQ (indefinite-delivery/indefinite quantity). Three companies submitted bids including the incumbent, Delfasco. An award was ultimately made to a different company; GTI whereupon Delfasco appealed the award on a number of grounds including the adequacy and sufficiency of past performance evaluations.

The Army evaluated both Delfasco's and GTI's past performance as "relevant" meaning that both had previously produced like or similar items. Like or similar items are defined as items that have been produced using similar manufacturing processes. However, the Army's support for these ratings did not correlate to the ratings themselves. In contrast with Delfasco's extensive experience producing these same items, the Army found that GTI lacked relevant past performance with respect to two necessary skills identified in the solicitation, and only somewhat relevant experience with respect to another skill.

Delfasco asserted that given the evaluated limits on GTI's experience (as indicated in the Army's evaluation), it was unreasonable for the Army to assign the same "relevant" rating assigned to Delfasco which had extensive experience.

The GAO sustained the protest. The GAO wrote that
In our view, the agency has not adequately explained, nor is it otherwise apparent, why GTI's limited relevant experience warranted a "relant" rating ("similar scope and magnitude of effort and complexities this solicitation requires") rather than a lower rating. For these reasons, we sustain the protest.
You can read the entire GAO decision here.

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