Metris LLC (B-422996.2)

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Category: SAM registration, Part 15 discussions

Date: 13 January 2025

URL: View decision

Metris LLC, a service-disabled veteran-owned small business, protested the Coast Guard’s termination of its award and its elimination from the competition under an RFP for training and instructional design services. DHS argued Metris failed to maintain an active registration in the System for Award Management (SAM) continuously from the submission of its initial proposal to the time of award. Metris countered that it was registered continuously from the submission of its final proposal revision (FPR), the operative "offer" for contract award under the FAR.

GAO examined whether the SAM registration requirement in FAR 52.204-7 applied continuously from the initial proposal or only to the operative FPR. GAO held that because Metris’s FPR superseded its initial proposal and Metris had a valid SAM registration from the FPR’s submission through award, the USCG’s decision was unreasonable. The ruling clarified that an FPR extinguishes prior proposals, and compliance with FAR 52.204-7 must be assessed based on the FPR.

The protest was sustained. GAO recommended that the USCG maintain the award to Metris and reimburse the company’s protest costs.

Digest

Protest challenging the proposed termination of the contract awarded to the protester and the protester’s elimination from the competition for failing to have an active registration in the System for Award Management continuously from the submission of its initial proposal through the time of award is sustained where the agency included the protester in the competitive range and the protester had a continuously active registration from the time of final proposal revision through the time of award.