SRM Group, LLC

DOCUMENT FOR PUBLIC RELEASE

The decision issued on the date below was subject to a GAO Protective Order. This redacted version has been approved for public release.

Decision

Matter of: SRM Group, LLC

File: B-423695

Date: September 25, 2025

Thomas K. David, Esq., and Lewis Rhodes, Esq., Reston Law Group, LLP, for the protester.
Richard W. Arnholt, Esq., Sylvia Yi, Esq., and Adam R. Briscoe, Esq., Bass Berry & Sims, PLC, for BryMak & Associates, Inc., the intervenor.
Robert B. Neill, Esq., Major Joseph A. Seaton, Jr., and Lieutenant Colonel Anthony V. Lenze, Department of the Army, for the agency.
Suresh S. Boodram, Esq., and Evan D. Wesser, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.

DIGEST

1. Protest challenging the evaluation of the awardee's past performance is denied where the agency's evaluation was reasonable and consistent with the terms of the solicitation.

2. Protest that the agency performed a flawed best-value determination is denied where the agency's tradeoff was reasonable and consistent with the terms of the solicitation.

DECISION

SRM Group, LLC, a service-disabled veteran-owned small business (SDVOSB) of Virginia Beach, Virginia, protests the award of a contract to BryMak Associates, Inc., an SDVOSB of Clarksville, Tennessee, under request for proposals (RFP) No. W912JF-25-R-A001, issued by the Department of the Army for lodging and transportation services. The protester contends that the agency's evaluation of the awardee's past performance was unreasonable and resulted in a flawed best-value determination.

We deny the protest.

BACKGROUND

On February 3, 2025, the agency issued the RFP for lodging and transportation services for the National Guard Professional Education Center (PEC) at Camp Robinson in North Little Rock, Arkansas. Agency Report (AR), Tab 17, RFP amend. No. 4 at 1; Tab 14, Second Amended Performance Work Statement (PWS) at 1.[1] Specifically, the contractor will be responsible for providing front desk services, housekeeping, laundry services, management of furniture and furnishings, pest control, custodial building and grounds maintenance, and transportation of students and guests staying in PEC lodging, as well as those who are billeted off-post. AR, Tab 14, Second Amended PWS at 1. The RFP, which the agency amended four times, was issued under Federal Acquisition Regulations (FAR) part 12 using the procedures of FAR part 15. AR, Tab 17, RFP amend. No. 4 at 10; Contracting Officer's Statement (COS) at 1-2. The RFP contemplated issuance of an SDVOSB set-aside, fixed-price contract with a 10-month period of performance and four 1-year options. AR, Tab 17, RFP amend. No. 4 at 1, 3, 12.

The RFP provided that award would be made on a best value tradeoff basis considering a number of price and non-price factors:

The Government intends to award to the offeror whose proposal receives the highest technical rating, provided that the offeror's proposed price is determined to be fair and reasonable using FAR 15 procedures. Technical is the most important factor, followed by Past Performance, and then Cost. The Government will select the offeror whose proposal demonstrates the highest overall value, considering the relative importance of these factors. It is the government's intent to award without discussions.

Id. at 10.

The RFP advised offerors that the agency “reserves the right to make award based upon the [c]ost/[p]rice factor in the event that the [t]echnical and [p]ast [p]erformance evaluation results of all the offerors' proposals are substantially the same.” Id. The technical factor included three subfactors: management plan; transition plan; and experience.[2] Id. at 12-13. Only the past performance factor is directly relevant to the issues presented in this protest.

As to past performance, offerors were to provide information for between two to five “recent and relevant” past performance contracts.[3] AR, Tab 17, RFP amend. No. 4 at 8. The RFP specifically contemplated that references could be submitted for the offeror or proposed subcontractors. See id. (“Organize [past performance] information by your company first, followed by each proposed subcontractor (alphabetical order).”). The RFP's instructions defined recent as work that was currently ongoing or completed within the last three years, and relevant as work “similar [in nature] to those required by the RFP's [North American Industry Classification System (NAICS)] code 561210 [(Facility Support Services)].” Id.

Relevant here, NAICS code 561210 includes:

[E]stablishments primarily engaged in providing operating staff to perform a combination of support services within a client's facilities. Establishments in this industry typically provide a combination of services, such as janitorial, maintenance, trash disposal, guard and security, mail routing, reception, laundry, and related services to support operations within facilities.

Office of Management and Budget, North American Industry Classification System, United States, 2022, at 486.

In addition to the solicitation instructions' definition of relevant past performance, the RFP's evaluation criteria provided that past performance contracts would be evaluated to determine recency, relevance, and confidence in the offeror's ability to successfully perform the RFP's requirements. AR, Tab 17, RFP amend. No. 4 at 12. As it relates to the issues presented in the protest, the RFP provided that relevancy would “not [be] separately rated,” but the agency would utilize the following criteria to determine the similarity of service/support, complexity, dollar value, contract type, and degree of subcontract/teaming:

Rating	Definition
Very Relevant	Present/past performance effort involved essentially the same scope and magnitude of effort and complexities this solicitation requires.
Relevant	Present/past performance effort involved similar scope and magnitude of effort and complexities this solicitation requires.
Somewhat Relevant	Present/past performance effort involved some of the scope and magnitude of effort and complexities this solicitation requires.
Not Relevant	Present/past performance effort involved little or none of the scope and magnitude of effort and complexities this solicitation requires.

Id. at 14.

As to the quality of an offeror's past performance, the agency would evaluate the overall quality of the offeror's past performance based on the agency's review of past performance questionnaires, interviews, Contractor Performance Assessment Reporting System (CPARS) reports and assign one of the following confidence ratings:

Rating	Description
Substantial Confidence	Based on the offeror's recent/relevant performance record, the Government has a high expectation that the offeror will successfully perform the required effort.
Satisfactory Confidence	Based on the offeror's recent/relevant performance record, the Government has a reasonable expectation that the offeror will successfully perform the required effort.
Neutral Confidence	No recent/relevant performance record is available or the offeror's performance record is so sparse that no meaningful confidence assessment rating can be reasonably assigned. The [o]fferor may not be evaluated favorably or unfavorably on the factor of past performance.
Limited Confidence	Based on the offeror's recent/relevant performance record, the Government has a low expectation that the offeror will successfully perform the required effort.
No Confidence	Based on the offeror's recent/relevant performance record, the Government has no expectation that the offeror will be able to successfully perform the required effort.

Id. at 14-15.

The agency ultimately received ten proposals, including from the protester and the awardee. AR, Tab 23, Source Selection Consensus Document (SSCD) at 1. After completing its evaluation, the agency assigned SRM Group's and BryMak's proposals the following ratings:

Evaluation Factor/Subfactor	SRM Group	BryMak
Technical Factor	Purple/Good	Purple/Good
Past Performance Factor	Substantial Confidence	Substantial Confidence
Total Evaluated Price	$24,059,013	$22,303,146

Id. at 2 (prices rounded to nearest dollar).

In his tradeoff analysis, the source selection authority (SSA) conducted a factor-by- factor comparison of the two firms' proposals, ultimately concluding that the proposals were essentially equivalent under the non-price factors. See id. at 16 (“BryMak offers the same technical risk, [and] an equally high past performance confidence assessment at a lower cost to the Government.”). Regarding the relevance of their respective experience, the SSA found that Brymak “clearly demonstrates experience providing lodging and transportation services that are greater [in] scope, magnitude and complexity compared to the [National Guard] PEC requirement[,]” including a subcontractor's prior experience providing housekeeping services [DELETED]. Id. at 15. For SRM Group, the SSA noted that the firm “is the incumbent contractor for this requirement and has successfully executed the performance requirements for 10 years.” Id. As to past performance, the SSA stated that both firms warranted substantial confidence ratings for their respective past performance based on the quality information reviewed by the agency. Id. at 16. The SSA ultimately concluded that SRM Group's proposal did not offer any additional performance benefits to warrant its approximately 7.8 percent price premium. Id. Therefore, the SSA selected Brymak's proposal for award. Id.

On June 20, 2025, the agency notified the protester that it had issued the contract to BryMak and provided a written debriefing. AR, Tab 25, Unsuccessful Offeror Notice at 1; Tab 26, Written Debriefing at 1. On June 27, the agency answered follow-up questions it received from the protester and provided the protester with a redacted copy of the source selection decision document (SSDD). AR, Tab 27, Enhanced Debriefing at 1. On July 2, the protester filed this protest with our Office.

DISCUSSION

SRM Group raises two primary protest grounds.[4] First, the protester challenges the reasonableness of the agency's past performance evaluation. Second, the protester argues that the agency's best-value tradeoff was unreasonable based on the underlying evaluation errors. For the reasons that follow, we find no basis to sustain the protest.

Past Performance Evaluation

SRM Group argues that the agency unreasonably evaluated the relevance of the three past performance references submitted by the awardee.[5] The protester contends that two of the past performance references should not have been considered relevant because the contracts involved work under a NAICS code different from the NAICS code identified in the RFP. Comments at 3-4. The protester also argues that a third reference, which was submitted for work performed by the awardee's subcontractor, should not have been considered relevant because the subcontractor has performed the contract for only a short period of time. Comments at 7. As addressed below, we find no basis on which to sustain the protest.

When a protester challenges an agency's past performance evaluation, we will review the evaluation to determine if it was reasonable and consistent with the solicitation's evaluation criteria, and procurement statutes and regulations, and to ensure that the agency's rationale is adequately documented. D&G Support Servs., LLC, B-419245, B‑419245.3, Jan. 6, 2021, 2021 CPD ¶ 15 at 8. An agency's evaluation of past performance, including its consideration of the relevance, scope, and significance of a vendor's performance history, is a matter of discretion, which we will not disturb unless the agency's assessments are unreasonable or inconsistent with the solicitation criteria. See Sterling Medical Assocs., Inc., B-418674, B-418674.2, July 23, 2020, 2020 CPD ¶ 255 at 8. A protester's disagreement with the agency's judgment, without more, does not establish that an evaluation was unreasonable. FN Mfg., LLC, B-402059.4, B‑402059.5, Mar. 22, 2010, 2010 CPD ¶ 104 at 7.

As addressed above and relevant to the issues presented in the protest, the RFP's instructions defined recent as “contracts currently ongoing or completed within the last 3 years[;]” and defined relevant as “services similar to those required by the RFP's NAICS code 561210.” AR, Tab 17, RFP amend. No. 4 at 8. As to relevancy, the RFP's evaluation criteria provided that it would be evaluated based on the “similarity [to the RFP] of service/support, complexity, dollar value, contract type, and degree of subcontract/teaming.”[6] Id.; see also id. at 8 (providing in the instructions to offerors that relevant past performance would be “similar [in nature] to those required by the RFP's NAICS code 561210 [(Facility Support Services)]).

BryMak submitted three past performance references, one that it self-performed and two that were performed by BryMak's proposed subcontractor. AR, Tab 18, Brymak Past Performance Proposal Volume at 7-12. The three contracts were for transportation lodging operations and janitorial housekeeping, all of which the agency found to be recent and very relevant to the solicitation's requirements. AR, Tab 23, SSCD at 8. The first reference was for BryMak's provision of transportation and motor pool services for the Department of Homeland Security (DHS), Federal Law Enforcement Training Center (FLETC). AR, Tab 18, BryMak Past Performance Proposal Volume at 7-8. The second reference was for the subcontractor's performance of dorm management services [DELETED]. Id. at 9-10. The third reference was for the subcontractor's provision of lodging and custodial services [DELETED]. Id. at 11-12. As noted, the agency found all of the awardee's past performance references to be very relevant and identified no weaknesses or deficiencies with the awardee's references. See, e.g., AR, Tab 22, Source Selection Evaluation Board (SSEB) Evaluation Report at 15. Based on its review, the agency assigned an overall past performance relevance rating of “very relevant” and a risk rating of “substantial confidence.” Id.

In challenging the evaluation of the awardee's past performance contracts, the protester first argues that the agency unreasonably evaluated two of the awardee's contracts as “very relevant” given that they were not performed under the specific NAICS code the solicitation used to define “relevant” past performance. Comments at 3-4. Specifically, the protester asserts that two of the awardee's contracts were performed under NAICS code 561720 (janitorial services), not under the RFP's NAICS code 561210 (facility support services), and therefore should not have been rated as “very relevant.” Id.

The agency responds that the RFP did not require past performance contracts to be classified under NAICS code 561210 and that the agency determined relevancy based on how similar the work under the reference was to the RFP. AR, Tab 28, Supp. Memorandum of Law (MOL) at 16-17. Therefore, it was reasonable for the agency to find contracts under different NAICS codes to be relevant to the work under the RFP when the work performed in the past performance reference aligned with the work required in the RFP. Id at 17-18.

We find no basis to question the agency's evaluation of BryMak's past performance. As noted above, the RFP defined relevant past performance to include “services similar to those required by the RFP's NAICS code 561210.” AR, Tab 17, RFP amend. No. 4 at 8 (emphasis added). Contrary to the protester's assertion, the RFP did not require past performance contracts to have been performed under NAICS code 561210; rather, the reference to this code merely described the nature of the agency's requirements. The agency's evaluation considered and documented the scope of the work performed on the efforts relative to the applicable requirements here. See, e.g., AR, Tab 22, SSEB Evaluation Report at 14-15; see generally Logistics Mgmt. Int'l, Inc., et al., B-411015.4 et al., Nov. 20, 2015, 2015 CPD ¶ 356 (agency evaluation of past performance references found unreasonable where the agency's past performance relevance determination did not extend beyond comparing the NAICS codes of the references to the solicitation's NAICS code).

The agency's relevancy rating for the two challenged references, which was based on this detailed comparison of the references to the requirements, was reasonable where BryMak's past performance references demonstrated that it involved work that reasonably matched the work required under the instant RFP. Compare, e.g., AR, Tab 14, Second Amended PWS at 17 (“Contractor shall provide a fleet of vehicles necessary to complete requirements in the PWS…”) with AR, Tab 18, Brymak Past Performance Proposal Vol. at 8 (“BryMak & Associates [was] responsible for all labor, equipment, materials . . . and other items and services necessary to support the operation of the Transportation Motor Pool (TMP).”). On this record, we find no basis on which to sustain the protest.[7]

The protester also argues that the agency unreasonably gave BryMak's proposal credit for one of the past performance contracts of its subcontractor because the contract had not been performed for a “substantive period of time.” Comments at 7. At the deadline for proposal submission, the awardee' s subcontractor had performed under the challenged contract for only three weeks, which, the protester argues, was not a sufficient amount of time for the agency to reasonably assess the quality of the subcontractor's performance. Id.

At the outset, we note that while the agency evaluated the relevancy of BryMak's third proposed reference, the record does not reflect that the agency considered the quality of performance for the reference as no CPARS record appears to exist for the reference. In this regard, the record reflects that the agency considered the proposed references and additional experience information submitted by each offeror under the experience subfactor and found that both offerors clearly address the agency's requirements. AR, Tab 22, SSEB Evaluation Report at 14-15, 16. Turning to past performance, the record reflects that the agency then considered the recency and relevancy for each proposed reference. Id. at 15, 16.

Next, the contemporaneous record reflects that the agency's assessment of the quality of the offerors' respective past performance was driven by the agency's consideration of available CPARS records for both offerors. For SRM Group, the agency had four available CPARS records for the firm's incumbent contract; the agency did not have quality-related information for SRM Group's other two references. See AR, Tab 22, SSEB Evaluation Report, at 16-17 (“SRM has 4 CPARS records that are rated as satisfactory or better.”); Tab 32, CPARS Records at 1. For BryMak the agency had access to 34 CPARS records, including for the awardee's own proposed reference, and 64 CPARS records for its proposed subcontractor, including on the subcontractor's other proposed reference, but not the challenged reference with the short performance duration. AR, Tab 22, SSEB Evaluation Report, at 15; Tab 32, CPARS Records, at 2-3 (reflecting ratings ranging from satisfactory to exceptional across all categories and rating periods). Thus, excluding contracts for both offerors that did not have sufficient quality information to support the agency's assessment of past performance confidence, the past performance evaluation effectively was limited to SRM Group's incumbent contract versus BryMak's and its subcontractor's two collective references, as well as the additional references identified by the agency's CPARS review. Under these circumstances, we find no basis on which to object to the agency's evaluation.

As noted above, BryMak's contract for the provision of motor pool and maintenance services was reasonably found to be very relevant as compared to the statement of work's (SOW) transportation requirements. Similarly, the subcontractor's other reference, which reflected uniformly very good ratings during the last CPARS assessment period, was specifically noted as being very relevant based on the provision of similar housekeeping and associated services [DELETED]. The SSA particularly noted that:

[DELETED] both organizations have similar missions and operate in a similar manner, I determined that the [DELETED] had essentially the same scope and complexities even though the [DELETED] might have been smaller on a dollar-for-dollar basis. For example, both contracts involved the complexities of operating a lodging facility in support of a military organization on a 24/7 basis; both contracts involved the complexities of managing a portfolio of hundreds of rooms; both contracts involved the complexities of interacting with ‘distinguished visitors' etc.

AR, Tab 23, SSCD at 15; see also AR, Tab 29, Supp. COS at 3.

Additionally, the contract specialist, who was the chair of the source selection evaluation board, represented that he was aware of other relevant contracts performed by the subcontractor based on the subcontractor's submission of a response to the sources sought synopsis (SSS) that the agency previously issued for this procurement, and his review of available CPARS records for BryMak and its subcontractor reflecting consistently positive past performance on contracts for similar services. See, e.g., AR, Tab 30, Decl. of Contract Specialist at 1; Tab 31, Subcontractor SSS Response at 6-11; Tab 22, SSEB Evaluation Report at 15 (generally identifying available CPARS records for BryMak and its subcontractor); Tab 32, CPARS Records at 3 (reflecting uniformly positive CPARS ratings for contracts conducted under, among other product service codes, S201 – Housekeeping – Custodial Janitorial, S216 – Housekeeping – Facilities Operations Support, S299 – Housekeeping – Other, Z1AA – Maintenance of Office Buildings, and Z1AZ – Maintenance of Other Administrative Facilities and Service Buildings). The protester does not advance any compelling objections to the agency's consideration of these other past performance references or why this aggregated data did not reasonably support the agency's overall confidence assessment.

On this record, we find no basis to sustain the protest. The evaluation of an offeror's past performance is within the discretion of the contracting agency, and we will not substitute our judgment for reasonably based past performance ratings. AAR Integrated Techs., B-416859.4, June 11, 2019, 2019 CPD ¶ 214 at 6. A protester's disagreement with the agency's judgment, without more, does not establish that the agency's judgment was unreasonable. Three Cities Mgmt., LLC, supra at 9. The record reflects that the agency reasonably took a holistic view of BryMak's and its subcontractor's past performance and found very relevant aggregated past performance that was supported by sufficient quality assessment information to warrant a rating of substantial confidence. Although SRM Group effectively argues that its incumbent contract, which was the only past performance reference supported by available quality assessment information, should have effectively been given decisive weight over the awardee's aggregated past performance, we disagree. We have explained repeatedly that a protester's apparent belief that its incumbent status entitles it to higher ratings provides no basis for finding an evaluation unreasonable, as there generally is no requirement that an offeror be given additional credit for its status as an incumbent, or that the agency assign or reserve the highest rating for the incumbent contractor. NLT Mgmt. Servs., LLC--Costs, B-415936.7, Mar. 15, 2019, 2019 CPD ¶ 122 at 6-7; PricewaterhouseCoopers Public Sector, LLP, B-415504, B-415504.2, Jan. 18, 2018, 2018 CPD ¶ 35 at 7. Therefore, we deny the protester's challenge to the agency's past performance evaluation.

Best-Value Determination

SRM Group alleges that the agency made an unreasonable best-value tradeoff decision because it relied on a flawed underlying past performance evaluation. As discussed above, we have reviewed the protester's challenges under the past performance factor and find no basis to disturb the agency's evaluation conclusions. Therefore, we deny this challenge to the best-value tradeoff decision.

The protest is denied.

Edda Emmanuelli Perez
General Counsel

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