PPQs Submitted Late? “No Problem,” Says GAO–At Least In One Case

While being fashionably late to a party may give the impression that one is a busy and popular person that was held up with other business, being fashionably late in federal contracting will typically have dire consequences.

However, a recent GAO bid protest decision demonstrates that when providing completed past performance questionnaires, or PPQs, being fashionably late may be acceptable – at least when the references were submitted directly by government officials, rather than the offeror.

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GAO: Agencies May Consider Outside Past Performance Information

When an agency requests that offerors provide past performance references, the agency ordinarily is not precluded from considering outside past performance information.

In a recent bid protest decision, the GAO confirmed that an agency’s past performance evaluation may include information outside the past performance references submitted by the offeror–and the agency can use any negative past performance information to downgrade the offeror’s score.

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Past Performance Reference From Sister Company Was “Inherently Biased”

In its evaluation of past performance, an agency was permitted to disregard a past performance reference prepared by an offeror’s sister company–which also happened to be in line for a subcontracting role.

In a recent bid protest decision, the GAO upheld the agency’s determination that the sister company’s reference was “inherently biased” and need not be considered in the agency’s past performance evaluation.

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Government References Didn’t Complete PPQs? “Too Bad,” Says GAO

Federal contractors frequently find themselves in the position of needing to establish their past performance credentials to secure future contracts – the government’s form of a reference check. The government often performs these reference checks by requesting completed past performance questionnaires, or PPQs, which the government uses as an indicator of the offeror’s ability to perform a future contract.

But what happens when a contractor’s government point of contact fails to return a completed PPQ? As a recent GAO decision demonstrates, if the solicitation requires offerors to return completed PPQs, the agency need not independently reach out to government officials who fail to complete those PPQs.

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When Agencies Don’t Return Past Performance Questionnaires: A Cautionary Tale

Past performance evaluations often hinge on government officials completing and returning past performance questionnaires.  But what happens when the government doesn’t return those PPQs?

In one case, at least, the answer was “nothing good.”  In a recent GAO bid protest decision, only two of six PPQs were returned for the lowest-priced offeror–and that offeror ended up losing the contract to a firm with a higher past performance score.

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