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Past Performance Remains Fertile Ground For Protest Challenges


In J.A. Farrington Janitorial Servs. (Oct. 18, 2005,, GAO found unreasonable the agency's assignment of a "high confidence" rating to the awardee of a grounds maintenance contract where the awardee's past performance references all related to efforts of far smaller magnitude and for only commercial customers. GAO also found that the agency's determination that the price offered by the protester, a HUBZone small business, was unrealistic amounted to a responsibility determination, and therefore had to be submitted to the Small Business Administration for a possible certificate of competency.

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Daniel R. Forman
Partner – Washington, D.C.
Phone: +1 202.624.2504