[Protest Against Army Contract Award for Respiratory Therapy Services]

A firm protested an Army contract award for respiratory therapy services, contending that: (1) its proposal was the most advantageous to the government; and (2) the Army improperly downgraded its proposal using evidence not included in its proposal. GAO held that: (1) the Army's consideration of evidence not included in the proposal was consistent with established procurement practices; and (2) since the solicitation listed references as an evaluation criterion, the Army properly considered the protester's unsatisfactory past performance. Accordingly, the protest was denied.