Teams Can “Flip-Flop” Prime and Subordinate Member Roles for Multiple Contracts
Two indefinite delivery/indefinite quantity contracts – one a small business set-aside and one unrestricted – were awarded to a team consisting of a small business and large business who flip-flopped their roles as prime and team member. An unsuccessful bidder protested alleging the awards were made to the same entity and hence competition would be precluded for future task orders because the two teams would be “competing against each other.” GAO rejected the same entity argument saying the two teams were not the same entity since they submitted a separate proposal for evaluation that included different labor rates, proportions of member participation as well as different management, small business participation plans and past performance information. The GAO went further and said even if they were the same there was no prohibition against making the award to teams even if they were the same (Global Readiness Enterprises, GAO B-284714).
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