[Claim for Payment of Services Rendered]

The General Services Administration (GSA) requested a GAO decision regarding a firm's claim for payment for providing press clippings to a Federal commission. After the commission's 1-month contract with the claimant for the services expired, the commission orally requested that the claimant continue to provide the services for 3 additional months. However, about 2 months after the formal contract expired and during which the claimant continued to provide the services, the commission informed the claimant that it was dissatisfied with its performance and stated that it was canceling the services retroactively. The claimant subsequently submitted invoices for payment for the entire period for which it provided services. There was nothing in the record to show the reasonable value of the work actually performed, which is the measure of quantum meruit payment. GAO held that the claimant may be paid only after GSA confirms that the claim reflects the services' reasonable value or otherwise establishes a reasonable value. However, since the commission expressly canceled the services after 2 months without a formal contract, the claimant should not be paid for services rendered after that time. Accordingly, the claim should be allowed for services rendered before they were expressly canceled.