Logan Currito, LLC (B-422729.2)

You should not care.

Category: Technical evaluation, past performance, best value tradeoff

Date: 23 December 2024

URL: GAO Case B-422729.2

Logan Currito, LLC, protested the VA’s award of a contract to Yellowstone Enterprises, LLC, for grounds maintenance services at Nashville National Cemetery. Logan Currito alleged that the agency improperly evaluated technical proposals, failed to credit past performance from key personnel and subcontractors, and conducted a flawed best-value tradeoff.

GAO upheld VA’s evaluation, noting that Yellowstone demonstrated superior experience, key personnel, and work/staffing plans. Yellowstone's proposal included current employees with relevant expertise and an approach emphasizing year-round service and new equipment, which VA reasonably found advantageous. GAO rejected Logan Currito's arguments that VA should have given greater weight to contingent hires and the experience of its subcontractor, Raven Operations, an unaffiliated entity. Additionally, GAO found no obligation for VA to credit Logan Currito with Raven Operations' past performance or that of individual employees. Finally, GAO ruled that the best value tradeoff properly prioritized technical factors over price, in line with the solicitation's terms.

GAO denied the protest finding VA's evaluation and tradeoff consistent with the solicitation, noting no errors or unreasonable actions in the process.

Digest

Protester’s challenge to the agency’s technical and past performance evaluations are denied where the record shows that the evaluations were reasonable and consistent with the terms of the solicitation.