Subcontractor Experience Irrelevant Where Subcontractor Won’t Perform Similar Tasks, Says GAO

Prime and subcontractor teaming is a common way for contractors to leverage the experience of the team’s anticipated subcontractors to make proposals more attractive to federal clients, particularly when past performance is a substantial evaluation consideration.

This approach, however, recently ran into a snag when the proposed subcontractor was not going to perform the discrete work areas that its past performance experience supported, which lowered the past performance score of the bid. In the resulting protest, GAO concluded the agency got the evaluation right, and was not required to credit all of the subcontractor’s experience.

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GAO Recommends Improvements For Comments on Proposed Federal Agency Rules

Have you ever felt like you were screaming into the void when submitting your comments to a proposed rule in the Federal Register? That your well thought out comments were being drowned out by a mass of other comments on a proposed rule or attributed to someone else? Have you wondered what agencies do with all that information you send them when you submit a comment on a proposed rule?

Well, GAO seems to have the same questions and concerns regarding the proposed rule comments process and has taken time these past few months to examine how agencies wade through comments on proposed rules, publish them, and clearly attribute identities to them.

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SmallGovCon Week In Review: November 4 – 8, 2019

It’s a busy travel period in our office. Just this week, I went to Warrensburg, Missouri for the Procurement Conference 2019 featuring Congresswoman Vicky Hartzler. It’s been great to chat with folks at these conferences.

Despite all the travel, we’ve been keeping up with federal contracting news. This week, we wanted to share a number of stories, including the Justice Department’s anti-price collusion “strike force”, a crackdown on supply chain cybersecurity, and the number of suspended and debarred contractors fell for the fourth year in a row.

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