Morrison Foerster’s Government Contracts Insights provides our in-depth analysis of developments and trends impacting government contracting. Through Insights, our attorneys offer a real-time assessment of the statutory, regulatory, legal, and business-related developments and trends that are shaping the industry. We also examine a full array of non-U.S. public procurement issues, mindful that our clients compete in a global marketplace.Morrison Foerster’s nationally recognized Government Contracts and Public Procurement practice represents the world’s leading companies in the aerospace and defense, intelligence, cybersecurity, information technology, financial and professional services, education, healthcare, infrastructure, and logistics support sectors. We are enlisted to address our clients’ most complex and important legal issues. Our work includes contract and subcontract negotiation and other transactional matters, business and regulatory compliance counseling, internal investigations, bid protests, and a wide array of enforcement and litigation matters. Our clients range from Fortune 50 companies to small and medium-sized companies just entering the public sector. We advise both U.S. and non-U.S. companies involved in municipal, state, federal, and non-U.S. procurement matters.<h2>ABOUT MORRISON FOERSTER</h2>Morrison Foerster is a leading global law firm that transforms complexity into advantage for its clients. Our clients include some of the largest financial institutions, banks, consulting and accounting firms, and Fortune 100, technology, and life sciences companies. Highlighting the firm’s commitment to client service, leadership in market-changing deals and impact litigation, and values-based culture, Morrison Foerster has been repeatedly recognized as one of the top 10 firms on The American Lawyer’s A-List. Year after year, the firm receives significant recognition from Chambers and The Legal 500 across their various guides, including Global, USA, Asia‑Pacific, Europe, UK, Latin America, and FinTech Legal. Our lawyers passionately care about delivering legal excellence while living our values. Morrison Foerster has a long-standing commitment to creating a culture that respects and celebrates differences, while providing an inclusive environment. The firm has achieved Mansfield Certification Plus since 2018 as a result of successfully reaching at least 30 percent women, communities of color, and LGBTQ+ lawyer representation in a notable number of current leadership roles and committees. The firm also has a long history of commitment to the community and society through providing pro bono legal services, including litigating for civil rights and civil liberties, improving public education and fostering the wellbeing of children, advocating for veterans, promoting international human rights, enforcing the right to asylum, and safeguarding the environment.

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Tina is Co-chair of Morrison Foerster’s Government Contracts & Public Procurement practice. She represents a wide variety of government contractors including information technology, defense, biotechnology, and pharmaceutical companies, with a focus on general contract counseling and compliance, particularly concerning intellectual property, and cybersecurity matters and federal grant funding.Tina counsels contractors on compliance with federal, state and local acquisition and ethics regulations and with the evolving myriad of requirements pertaining to data security and cybersecurity. She has been involved with numerous internal investigations and compliance reviews, and with mandatory and voluntary disclosures to agencies, and litigation of False Claims Act matters.Tina routinely advises clients concerning:<ul><li>Prime-subcontractor relationships</li><li>Sources of supply and country of origin requirements</li><li>Price reductions and price reporting issues</li><li>Organizational conflicts of interest</li><li>Safeguarding of intellectual property and other proprietary interests</li><li>Licensing and data rights issues</li><li>Handling of classified materials and controlled unclassified information</li><li>Agency suspension and debarment proceedings</li></ul>She also assists clients with due diligence and other activities related to the acquisition of government contracting concerns, and with the drafting and negotiation of teaming agreements, subcontracts, licensing agreements, and cooperative research and development agreements. She also assists clients applying for federal grants (including SBIR and STTR agreements), and those who seek to obtain other transactional authority agreements, as well as those competing for state and local government work.Tina’s litigation experience includes government contracts claims litigation in federal courts and before boards of contract appeals, bid protests before the Government Accountability Office and the Court of Federal Claims, and complex disputes in federal courts, including civil fraud and False Claims Act litigation and reverse Freedom of Information Act litigation.Prior to joining Morrison Foerster, Tina worked at another large national firm and as a trial attorney in the Office of the General Counsel of the Navy, Navy Litigation Office.<h4>Representative Experience</h4><ul><li>Negotiation of largest CHIPS Act federal funding agreement between multinational semiconductor corporation and U.S. Department of Commerce.</li><li>Negotiated prime contract and major subcontracts related to the Department of Energy’s next generation supercomputer program, including extensive IP rights negotiations and negotiation of associated patent rights waivers.</li><li>Negotiated series of other transaction authority agreements with DARPA and associated subcontracts with more than a dozen research universities on behalf of a firm biotech client, including complex IP rights allocations and material transfer agreements.</li><li>Assist clients with FedRAMP authorization process and with development of license agreements for software products sold to federal, state and local government agencies.</li><li>Cyber incident response counseling to some of the largest companies and organizations impacted by security incidents.</li><li>Advises clients on Bayh-Dole reporting of inventions and IP strategies for contracts and grants.</li><li>Conducts due diligence for major government contract mergers and acquisitions.</li></ul>

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Tina is co-chair of Morrison Foerster’s Government Contracts & Public Procurement practice. She counsels a wide variety of government contractors on compliance with federal acquisition and ethics regulations. She drafts and negotiates contracts on their behalf and has been involved with numerous internal investigations and compliance reviews, and with bid protest, contract claims, and False Claims Act litigation. She also advises on M&A transactions involving government contractors.

Tina D. Reynolds

Jim Tucker is of counsel in Morrison Foerster’s Government Contracts and Public Procurement Practice Group and is based in the firm’s Washington, D.C. office.Jim’s practice runs the gamut of litigation and counseling in federal procurement matters, with an emphasis on bid protests, Cost Accounting Standards disputes, and small business matters. He has represented both protesters and awardees in scores of protests before the Government Accountability Office, the Court of Federal Claims, and procuring agencies, in acquisitions ranging from small business procurements to multibillion-dollar contracts of global significance. His representative protest matters span the aerospace sector, the Intelligence Community, base operations and logistics, healthcare, nuclear and environmental work, and information technology and software acquisitions. His protests have included both classified and unclassified programs. In addition to prevailing in published decisions, Jim has also secured favorable corrective action on behalf of clients in a wide variety of protests that were resolved without a published decision.Jim’s work also focuses on disputes over cost allowability and compliance with the Cost Accounting Standards, and he has appeared before the Armed Services and Civilian Boards of Contract Appeals, in size and status protests before Small Business Administration (SBA) area offices, and appeals before the SBA Office of Hearings and Appeals. Jim regularly counsels clients on contract interpretation, organizational conflicts of interest, and small business compliance.Jim graduated with high honors from the George Washington University Law School, where he focused his studies on federal procurement law, was a member of the Law Review, and interned with the General Services Administration’s suspension and debarment office. Jim also holds a degree in theology magna cum laude from the Pontifical Gregorian University in Rome and a bachelor’s degree in classical languages and literature summa cum laude from the University of Kentucky, where he graduated Phi Beta Kappa.

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Jim maintains an active practice in bid protests before the Government Accountability Office and contracting agencies and counsels clients in contract disputes and compliance obligations.

Jim Tucker is of counsel in Morrison Foerster’s Government Contracts and Public Procurement Practice Group and is based in the firm’s Washington, D.C. office. Jim’s practice runs the gamut of litigation and counseling in federal procurement matters, with an emphasis on bid protests, Cost Accounting Standards disputes, and small business matters.

James Tucker

<div style="margin-bottom: 15px;" class="videoWrapper"><iframe class="sticky-video" title="Meet Alex Ward, Government Contracts Practice Co-Chair" src="https://www.youtube-nocookie.com/embed/TkliwdSlTaQ?rel=0" frameborder="0" allow="autoplay; encrypted-media" allowfullscreen="1" title="iframe"></iframe></div>J. Alex Ward is co-chair of Morrison Foerster’s Government Contracts and Public Procurement group. His practice covers a full range of government contracts matters, including investigations, bid protests, claims, general litigation, corporate transactions, and counseling. Alex strives in all matters is to provide his clients the highest level of efficient and effective representation.Alex represents contractors in internal and external investigations, disclosures to the government, and qui tam litigation, with great success in reducing or eliminating his clients’ exposure through active engagement with the government. His work in this area includes obtaining numerous declinations and dismissals of False Claims Act cases in their earliest stages, sparing his clients the cost, risk, and exposure of litigation.He has also served as lead counsel in dozens of bid protests involving military and civilian agency procurements of a wide range of products and services, including all manner of pre- and post-award protests in the GAO, the U.S. Court of Federal Claims, and state tribunals, as well as appeals to the U.S. Court of Appeals for the Federal Circuit and size protest appeals before the SBA’s Office of Hearings and Appeals.Alex handles all aspects of the claims process, from the initial assessment and drafting of requests for equitable adjustment through litigation in the Boards of Contract Appeals and the Court of Federal Claims. Alex’s practice also covers the full gamut of other controversies confronting government contractors, including prime-sub, teaming partner, employer-employee, competitor, and indemnification disputes. His litigation work also includes a wide variety of pro bono engagements, in which he has represented both individual and institutional clients in matters ranging from immigration and criminal defense to sustainable procurement and protection of the environment.Prior to joining the firm, Alex served in the U.S. Army as a commissioned officer and an Assistant to the General Counsel of the Army responsible for civil works and international matters, and as a clerk for judges on the U.S. Courts of Appeals for the Armed Forces and the D.C. Circuit. He is a member of the Boards of the Morrison & Foerster Foundation and the Chesapeake Bay Foundation and of Law360’s Government Contracts Editorial Board.

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Alex is co-chair of Morrison Foerster’s Government Contracts and Public Procurement practice. His practice covers a full range of government contracts matters, including bid protests, claims, investigations, corporate transactions, and counseling.

J. Alex Ward

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Morrison Foerster’s Government Contracts Insights blog provides an in-depth analysis of news, developments, and trends impacting government contracting and procurement. Through Insights, attorneys from our nationally recognized Government Contracts and Public Procurement practice will offer a real-time assessment of the statutory, regulatory, legal, and business-related developments that are shaping the industry. This blog will also examine a full array of U.S. and non-U.S. public procurement issues, mindful that our clients compete in a global marketplace.Read about our <a href="http://govcon.mofo.com/editors/">Authors</a>.Never miss a post. Subscribe to get real-time updates.

Brad is a partner in Morrison Foerster’s Litigation Department, Managing Partner of the Austin office, and Chair of the firm’s Israel practice. He is the former Co-Chair of the firm’s Global Litigation Practice and the Government Contracts + Public Procurement Practice.

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This month’s Bid Protest Roundup focuses on a recent U.S. Court of Federal Claims decision involving the limitations of the government’s deference defense and a U.S. Government Accountability Office (GAO)  that involved the proper application and discretionary nature of the so-called close-at-hand principle.

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September 2023 Bid Protest Roundup: Limits to Agency Discretion in Challenge to NAICS Code Assignments, Confines of the Close-at-Hand Principle | Government Contracts Insights

Roke Iko

This month’s Bid Protest Roundup focuses on a recent U.S. Court of Federal Claims decision involving the limitations of the government’s deference defense and a U.S. Government Accountability Office (GAO)  that involved the proper application and discretionary nature of the so-called close-at-hand principle.Consolidated Safety Services, Inc. v. U.S.In Consolidated Safety Services, the Court of Federal Claims rebuked the National Oceanic and Atmospheric Administration for a solicitation’s improper North American Industry Classification System code assignment.[i] The court held that NOAA’s assignment was arbitrary, capricious and contrary to Small Business Administration regulations.  Consolidated Safety Services is a reminder that agencies do not have unlimited discretion when selecting NAICS codes for their procurements. More broadly, the case reflects that even a generally reasonable agency decision may be considered arbitrary and capricious if the agency neglects to adhere to relevant statutes and regulations. Statutes and regulations provide essential criteria that an agency must strictly follow and by which its decisions are assessed. Overview of NAICS CodesThe NAICS codes consist of six‑digit numbers and classify businesses based on their primary economic activities.The SBA uses NAICS codes to assess businesses’ eligibility for small business contracting preferences in government procurement.  The SBA assigns specific NAICS codes to industries and sets size standards based on either annual revenue or number of employees, depending on the industry.Relevant FactsOn February 17, NOAA issued a solicitation that contemplated the award of a single blanket purchase agreement with the express purpose of obtaining “necessary scientific, technical, and administrative services to efficiently and effectively support the mission and goals of [the National Centers for Coastal Ocean Science].”[ii]The agency classified the solicitation under the NAICS code for environmental consulting services, which carries a size standard of $19 million in average annual receipts. The disappointed offeror, Consolidated Safety Services, or CSS, could not compete for the procurement because its annual receipts exceeded that amount.CSS filed a NAICS Appeal with the SBA’s Office of Hearings and Appeals, or OHA, arguing that the solicitation primarily involved “performing research, not advising the agency about research.”[iii]  Thus, CSS argued, the agency should have categorized the solicitation under the NAICS code for research and development which has a size standard of 1,000 employees and under which CSS would be considered a small business. The OHA affirmed the agency’s selection of the NAICS code for environmental consulting services. Subsequently, CSS filed a bid protest lawsuit in the Court of Federal Claims, maintaining that the solicitation should be classified under the code for research and development.Court of Federal Claims’ AnalysisIn a lengthy opinion, Judge Matthew Solomson methodically dissected NOAA’s and OHA’s analysis, overturning OHA’s decision and holding that the agency’s environmental consulting services NAICS code designation was contrary to SBA regulatory requirements and that the research and development NAICS code was more suitable.  The court ruled that the solicitation predominantly sought scientific research and experimental development services. This conclusion was evidenced by dozens of research-oriented tasks and subtasks within the solicitation and the fact that over 85% of the solicitation’s labor hours were allocated to various types of research scientists.Critically, the court explained that SBA regulations do not provide the government with maximum discretion to select any reasonable NAICS code — the contracting officer must designate “the proper NAICS code and corresponding size standard in a solicitation, selecting the single NAICS code which best describes the principal purpose of the product or service being acquired.”[iv] While the court acknowledged that the SBA regulations do not require the contracting officer to select the perfect NAICS code  and reasonable minds may disagree, it found that the SBA regulations do require the court to consider whether the contracting officer and OHA reasonably concluded that the NAICS selected was the best description of the solicitation. Thus, the government cannot substantiate its selection of a particular NAICS code simply by asserting that it broadly aligns with the procurement or because the selection is deemed adequately suitable for government work. Further, SBA regulations limit the government’s discretion by noting that procurements are generally classified by NAICS code according to the component that accounts for the greatest percentage of contract value.[v]It is against these limitations that the court considered whether the agency had properly determined the NAICS code.The court found that NOAA and OHA erred in concluding that the solicitation did not seek research and development services. In its analysis, the court looked to the definition of “research” in the NAICS manual, the solicitation provisions that addressed providing administrative, scientific, and technical support to ensure timely delivery of research products, and at the specific tasks and subtasks listed in the solicitation that repeatedly mentioned research in some capacity. In comparison, the solicitation listed very few references to consulting services. In the court’s assessment, neither NOAA nor OHA adequately explained, with reference to the criteria imposed by the SBA regulations, why the NAICS environmental consulting services code best described the work solicited, when the NAICS research and development code was a much better match.The court was especially critical of OHA’s sparse, two-page analysis, which it found erroneously ignored important facts and solicitation details. As the judge stated, OHA’s decision “flatly ignores scores of tasks in the Solicitation that naturally fit the definitions of ‘research’ and ‘experimental development.’”[vi]  The court also took OHA to task for failing to grapple with its own conflicting case precedent on when NAICS research codes should apply. Due to the multiple factual errors, legal flaws, and omissions in OHA’s cursory decision affirming NOAA’s consulting services NAICS code, the court held that OHA acted in an arbitrary and capricious manner.  The court then enjoined the procurement from proceeding under the improper NAICS code and remanded the case to OHA for reconsideration.TakeawaysAlthough Consolidated Safety Services centers on agency NAICS code assignment, it considers the larger theme that agencies are required to adhere to certain regulations and government discretion. This case demonstrates that there are limits to the government’s deference defense. Agencies must offer reasoned justifications rooted in concrete facts and regulatory selection criteria. Explanations that ignore key evidence or past precedent will likely not survive judicial scrutiny.VectorCSP LLCVectorCSP LLC serves as a reminder of the boundaries of the “close-at-hand” principle in evaluating information known to agency personnel but not explicitly included in a proposal.[vii] Vector, the protestor, argued — unsuccessfully — that proposal evaluators should factor their prior knowledge of a predecessor contract, performed by Vector’s subcontractor, into their evaluation of its proposal. This protest emphasizes the risk of relying on evaluators’ presumed knowledge instead of submitting a thoroughly detailed and comprehensive proposal.Close-at-Hand PrincipleThe GAO recognizes the so-called close-at-hand principle, which requires agency evaluators to use their own knowledge when evaluating past performance on work that is “too close at hand” to the current procurement, even if the past performance is not explicitly mentioned in the company’s proposal.For example, if an offeror mentions a previous contract, evaluators may already know details and quality of the past performance under that contract due to their personal experience. In such cases, agencies must use their existing knowledge during the evaluation process.However, this principle does not require agencies to actively seek information beyond what is provided in the company’s proposal for the current procurement. Offerors are responsible for including detailed information in their proposals to ensure a thorough evaluation.  Additionally, the GAO has stated that the close-at-hand principle applies to past performance, but not technical matters.Vector’s ProtestIn Vector, the U.S. Coast Guard issued a task order request for proposals seeking contractor engineering support services. The solicitation outlined three evaluation factors in descending order of importance: corporate experience, management approach, and price. Under corporate experience, offerors were required to include up to four references showing experience similar in complexity and scope to the solicitation, with one reference showing the offeror had performed as the prime contractor. The agency evaluated the proposals and selected THOR Solutions LLC based on its corporate experience and management approach, despite its higher price. Vector filed a bid protest, alleging disparate and unreasonable evaluation of the technical proposals, and a flawed best-value tradeoff. Specifically, under the corporate experience evaluation, Vector challenged the agency’s contention that its second reference, related to the proposed subcontractor’s performance on a predecessor contract, was not relevant. The Coast Guard argued that Vector’s proposal failed to provide the required documentation to consider the scope of the work actually performed, as specified in the solicitation.The GAO disagreed with Vector on all allegations. Particularly relevant was its discussion of the “close‑at‑hand” issue. Vector argued that the agency was unreasonable in deeming the contract reference about its proposed subcontractor as irrelevant and asserted that the agency “entirely ignore[d] that the contract reference is the predecessor to the incumbent contract.”[viii] Vector claimed that this information was “too close at hand” to disregard. However, the GAO clarified that “close-at-hand” information is limited to past performance and does not extend to an experience evaluation. Evaluation under a corporate experience factor is distinct from evaluation of past performance—Under corporate experience, agencies consider an offeror’s technical ability to do the work. The solicitation at issue in Vector provided that references for corporate experience should show “similar technical difficulty, show relevant requirements, and show the company’s experience providing . . . capabilities similar to the requirements of the solicitation.”[ix] In contrast, evaluation under a past performance factor often focuses on the quality of the work performed.  Furthermore, it is the offeror’s responsibility to submit a well-written proposal that can be adequately evaluated; the agency is not obligated to consider close-at-hand information. Here, Vector had failed to provide the required documentation to be properly evaluated. Thus, the allegation was denied.TakeawaysVector illustrates the importance of providing comprehensive details, descriptions and explanations in proposals, rather than hoping evaluators will supplement what is provided with their personal knowledge. Given the discretionary nature of the close-at-hand principle, relying on evaluators to fill gaps in a proposal with their unstated knowledge is risky. While the close-at-hand doctrine may require agencies to consider relevant past performance experience not explicitly referenced in a proposal, under certain circumstances, the doctrine is limited only to past performance. Although corporate experience is very similar to past performance, the GAO has consistently held that they are different things, and the close-at-hand doctrine does not apply to corporate experience evaluations.Even for past performance evaluations, the close-at-hand doctrine applies only in instances where the evaluators have personal knowledge of the past performance and where the protester did not bear the burden of providing more information in its own proposal. There is no substitute for a well-written proposal. If citing a previous contract with which the agency is familiar, offerors should do more than mention the name or number and assume that the similarities are apparent. Offerors should thoroughly explain why the previous contract is relevant and how it correlates to the instant requirement.For IDIQ contracts or BPAs, documentation of specific task orders performed may be necessary. Offerors should not just reference the overall vehicle and expect evaluators to make the connection; they should include all relevant documentation.[i] Consol. Safety Servs., Inc. v. U.S., No. 23-521C, 2023 WL 6173385 (Fed. Cl. Sept. 22, 2023).[ii] Id. at *4.[iii] Id. at *5.[iv] Id. at *2 (citing 13 C.F.R. § 121.402(b)).[v] Consol. Safety Servs. Inc., No. 23-521C, 2023 WL 6173385 at *2 (citing 13 C.F.R. § 121.402(b)(2)) (citation omitted).[vi] Id. at *10.[vii] VectorCSP, LLC, B-421764, B-421764, 2023 WL 6477744 (Sept. 27, 2023).[viii] Id. at *8.[ix] Id. at *2.

September 2023 Bid Protest Roundup: Limits to Agency Discretion in Challenge to NAICS Code Assignments, Confines of the Close-at-Hand Principle

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