Both the FAR and GAO decisions distinguish between prior experience and past performance even though agencies sometimes evaluate the two together. For example, an agency reasonably evaluated the comparative degree of relevance of the past contract experience of offerors under the experience factor but not under the past performance factor as outlined in the solicitation’s evaluation scheme (Oceaneering Intl. Inc. B-287325). In any evaluation, evaluators should be aware there is a distinction between experience and past performance where experience is an objective evaluation because the issue is whether the firm previously has performed the requisite work. Past performance, however, is considerably more open to interpretation. For example, in a competition for operating, maintaining and repairing Pentagon heating and refrigeration plant, the GAO held the agency unreasonably eliminated the protester’s proposal as technically unacceptable based on the firm’s lack of past performance in performing the services in a facility comparable to the Pentagon. The GAO held that under the RFP’s past performance evaluation factor, the agency appeared to be more concerned with the protester’s alleged lack of relevant experience rather than the quality of its performance since the agency neither received nor was aware of any negative past performance reports (Consolidated Eng’g Servs. Inc. B-291345). The procurement regulations also differ. Although evaluation of prior experience is one of the factors that may or may not be evaluated to satisfy the contract requirements, past performance must be evaluated in all source selections for negotiated competitive acquisitions expected to exceed $100,000 (FAR 15.304(c)(3)(ii)

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