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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In our bid protest roundup for March, we consider three recent decisions of the Government Accountability Office (GAO).  The first explains why similar proposals for similar requirements under similar evaluation criteria may legitimately receive very different ratings from one procurement to the next.

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March 2024 Bid Protest Roundup: “Each Procurement Stands on Its Own”; Responsibility Determinations; Trade Agreement Act Compliance | Government Contracts Insights

James A. Tucker

In our bid protest roundup for March, we consider three recent decisions of the Government Accountability Office (GAO).  The first explains why similar proposals for similar requirements under similar evaluation criteria may legitimately receive very different ratings from one procurement to the next.  The second decision illustrates the risk an agency assumes when its corrective action ignores a protester’s plausible allegations and when the documented procurement record does not support the agency’s litigation position.  The final decision examines how a protester can be right about an awardee’s prospective noncompliance with requirements but still lose the protest.Royal Bridge, Inc., B-422263Royal Bridge was a single-issue protest addressing a question that proposal teams frequently ask.  If the same agency has previously run a similar procurement for the same requirements, using the same evaluation criteria, and an offeror submits a materially identical proposal for each procurement, shouldn’t the offeror end up, more or less, with the same adjectival ratings in both competitions?  The answer is: not necessarily.The protester submitted a proposal to the Army Corps of Engineers for the rehabilitation of certain flood gates at a dam in Arkansas.  For the Technical Approach and Organization evaluation factors, the agency rated the protester’s proposal as Acceptable.  It rated the eventual awardee’s proposal as Acceptable and Outstanding for these same factors.  After consideration of the other evaluation factors, the agency chose not to award the contract to the protester.The protester argued its proposal deserved ratings higher than Acceptable for the Technical Approach and Organization factors.  Four years earlier, the protester submitted a similar proposal to the same agency for similar rehabilitation services at another dam in Arkansas and received higher than Acceptable ratings in that competition.  The protester argued:<blockquote>A reasonable and consistent evaluation would not have resulted in such a variance in evaluation ratings in such a short period of time when the differences in the requirements of the two projects were so minimal, and the Protester’s capabilities were identical for each project.</blockquote>The agency argued that the earlier proposal and procurement were somewhat different, but the GAO found it unnecessary to resolve that question.  Even if the proposals and requirements had been identical in the two procurements, the protester would not prevail.  Under GAO decisional law, “as a general matter, it is not unusual for individual evaluators to reach different conclusions and assign different scores or ratings when evaluating proposals, since both objective and subjective judgments are involved.”  As a result, “evaluation ratings under another solicitation are not probative of the alleged unreasonableness of the evaluation ratings under the solicitation at issue, given that each procurement stands on its own.”Because of this rule, a prior evaluation outcome in an earlier procurement is not “precedential” for subsequent procurements.  If the evaluators in the first procurement rated the protester’s proposal as Outstanding, that does not mean that evaluators in a later procurement for the same requirements must do the same, even if the proposals and solicitations are essentially the same.  As the GAO noted, although there are certain objective aspects to most evaluations, they are usually mingled with a strong dose of subjective judgment.If the evaluators’ judgments are reasonable, considering only the current procurement, and are consistent with the terms of the solicitation and governing regulations, the GAO generally will not second-guess the evaluators’ adequately documented judgments.  This has more to do with the reasonableness of the process than with the outcome of that process.  The fact that reasonable minds may disagree with the outcome—or even that they did disagree in an earlier procurement—is not a basis for sustaining a protest.Takeaway: As a practical matter, proposal teams often use past competitions to inform their strategies for similar competitions conducted by the same agency.  This may be a sensible proposal strategy but does not guarantee a predictable result.  Each procurement stands on its own, and no offeror is guaranteed the same agency will make the same discretionary evaluation choices in a future procurement, even if a company proposed the same thing both times.MVM, Inc., B-421788.3, B-421788.4MVM involved a General Services Administration (GSA) procurement of transportation services for the Department of Health and Human Services.  After an initial award to Acuity International, LLC, MVM, Inc. filed a protest.  MVM alleged, among other things, that GSA’s responsibility analysis failed to consider that one of Acuity’s affiliates recently settled a False Claims Act (FCA) matter with the Department of Justice.GSA fought the protest.  After briefing was complete, the assigned GAO attorney conducted outcome prediction and advised the parties that multiple aspects of the GSA evaluation appeared to be unreasonable or inadequately documented, rendering the award unsupportable.  The GAO did not identify the FCA-related ground as clearly meritorious, as the contracting officer did not appear to have any knowledge of that issue before award.  GSA, after learning it likely would lose the protest, took voluntary corrective action and thereby mooted the protest.Following corrective action, GSA again awarded the task order to Acuity, and MVM again protested.  The updated procurement record evidenced no consideration of the FCA issue MVM had brought to GSA’s attention in the prior protest.  Although the contracting officer may have been unaware of the issue at the time of the initial award, GSA now had actual notice of the issue as a result of the prior protest.  Recent settlement of a potential fraud would be expected to have a strong bearing on whether the awardee should be found responsible.  MVM argued that, under these facts, it was unreasonable for GSA to ignore this issue during corrective action.  Rather than take voluntary corrective action again, GSA fought the protest.The GAO found that not only was the record inexplicably silent about the FCA matter, but even the contracting officer’s litigation response ignored it.  Although GSA’s attorney asserted that consideration of the matter “would not change” GSA’s favorable view of the awardee’s responsibility, the GAO disregarded this assertion as an after-the-fact conclusion first developed in the heat of litigation.  The documented record provided no basis for the GAO to find that the GSA had reasonably evaluated the awardee’s responsibility.MVM also challenged the awardee’s candidate for the lead project director position.  The protester argued that the awardee’s proposal failed to demonstrate that its candidate for this key personnel position had five years of management experience with advanced levels of financial responsibility, which the solicitation required.  GSA responded with a conclusory assertion that the candidate “clearly met all requirements of the solicitation.”The GAO found the record did not support GSA’s assertion.  Although the evaluator worksheets all stated verbatim that there was “[n]o doubt that this offeror’s key personnel hold the appropriate credentials and have sufficient experience to oversee the project,” nothing in the record supported that bare conclusion.  GSA argued that the candidate’s resume showed he met the requirements because he held positions as “a director for an Indian Tribe wellness center and as an interim director for a county public health and social services department.”  The GAO was unpersuaded, however, because the record showed the awardee’s candidate held these positions for only 26 months—far short of the five-year requirement that GSA claimed he met.  Therefore, the GAO sustained the protest on this basis, as well.Takeaway: It is difficult to succeed in challenging an agency’s affirmative responsibility determinations, and the GAO generally will not even consider such allegations.  Protesters may succeed when, as here, an agency unreasonably ignored available information that, by its nature, might be expected to have a strong bearing on whether a company is responsible.  It is puzzling why GSA’s corrective action failed to address this issue, which the initial protest placed squarely before it.  This protest also highlights the importance of making sure that one’s proposal plainly demonstrates how each key person meets minimum requirements, as well as the folly of an agency’s fighting a protest where the record is inconsistent with the agency’s litigation position.W&K Container, Inc., B-422234.2This month’s final case involves compliance with the Trade Agreements Act (TAA).  The Defense Logistics Agency (DLA) sought transoceanic shipping containers compliant with the TAA, in accordance with Defense Federal Acquisition Regulation Supplement (DFARS) 252.225-7021.  This TAA provision mandates, among other things, that end products delivered to the government (here, the containers) be produced only in the United States (U.S.), qualifying countries, or designated countries.  As relevant here, the Republic of Korea is a designated country, and China is not.  The solicitation cautioned offerors that it might reject any proposal offering end products that were not TAA-compliant.After receiving proposals, DLA awarded the contract to Intrepid Eagle Logistics, Inc. at a price of $8,602,000 for the first lot of containers.  Intrepid’s proposal listed the Republic of Korea as the place of manufacture of its end products.  W&K Container, Inc.’s offer, priced at $9,530,400 for the first lot, was unsuccessful.  W&K’s proposal identified its containers as also manufactured in Korea.  Following a debriefing, W&K protested the award.  W&K alleged that the awardee’s proposed containers were not TAA-compliant.  The protester argued that Intrepid’s low price was due to proposing Chinese-manufactured container kits, which might subsequently be assembled (but not substantially transformed) in a TAA-designated country like Korea, in violation of the TAA.  W&K noted it raised this same concern about Intrepid in an agency-level protest to DLA under an earlier procurement.On the same day W&K’s post-award debriefing concluded, DLA asked Intrepid where exactly the awardee’s container components originated, and where and how those components were transformed into the final end products.  The awardee’s answers led DLA to conclude Intrepid’s containers would not be TAA-compliant.  DLA found that Intrepid’s containers would be the products of a non-designated country, and that their subsequent assembly in a designated country would not “substantially transform” them into end products of that designated country.While W&K’s protest was pending, DLA issued a cure notice to Intrepid.  Intrepid responded with a corrective action plan and a certification that its corrected product and processes would comply with the TAA.Although the protester was correct about the awardee’s noncompliance with the TAA, the GAO nonetheless denied the protest.The GAO found that nothing on the face of Intrepid’s proposal put DLA on notice of the noncompliance: the proposal contained the required TAA certification and identified the end products’ place of manufacture as a TAA-designated country.  The GAO cited its rule that an agency generally may rely on an offeror’s representations and certification of TAA compliance without further investigation, unless the agency has reason to believe before award that the offeror will not supply a compliant product.  Absent such a reason, an offeror’s intended compliance or noncompliance is a matter of contract administration, which is outside the scope of the GAO’s bid protest function.The protester countered that DLA had reasons to doubt Intrepid’s compliance.  First, W&K raised identical concerns about Intrepid’s TAA compliance with this very agency just two years earlier.  The GAO found this argument unconvincing because “each procurement stands on its own,” and W&K’s earlier protest was legally irrelevant.  The GAO also noted that the contracting officer for the prior procurement was different from the one assigned here.The GAO also rejected the protester’s argument that Intrepid’s “very low price” should have tipped off DLA that Intrepid would supply cheap and noncompliant Chinese goods.  In a fixed-price procurement such as this, without price realism provisions, the contracting officer correctly declined to draw adverse conclusions from an offeror’s low proposed price.Finally, the GAO rejected the protester’s complaint about DLA’s post-award exchanges, which allowed the awardee to cure its noncompliance with the TAA.  The GAO found that these post-award exchanges were, under these facts, unobjectionable matters of contract administration and not matters for a bid protest.Takeaway: Although the protester correctly deduced that its rival’s approach would not comply with the TAA, the protest nevertheless failed because a GAO protest generally will not consider matters of contract administration.  Some agencies might have taken voluntary corrective action under these facts.  But, by fighting and winning, DLA will get TAA-compliant containers at a made-in-China price, making it perhaps the only winner in this protest.

March 2024 Bid Protest Roundup: “Each Procurement Stands on Its Own”; Responsibility Determinations; Trade Agreement Act Compliance

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