In Advanced Computer Learning Company, LLC, B-423267.2 (September 2, 2025), Advanced Computer Learning Company (ACLC), the incumbent contractor, protested the Navy’s award of a support services and data link training contract to Linchpin Solutions, Inc., challenging the agency’s evaluation of past performance and the resulting best-value tradeoff. ACLC argued that it was irrational for the Navy to assign Linchpin the same “Substantial Confidence” rating it received, despite ACLC’s strong performance as the incumbent on the exact requirement.
ACLC claimed the agency improperly elevated Linchpin’s rating by aggregating multiple smaller or less relevant past performance references, improperly credited Linchpin for work actually performed by its subcontractors on those references, and relied on the contracting officer’s personal knowledge rather than the contents of Linchpin’s proposal. In ACLC’s view, these issues distorted the evaluation and skewed the award decision. GAO, however, disagreed and denied the protest in full, finding that the Navy’s evaluation approach was consistent with the solicitation and that the award decision was reasonable and adequately documented.
The Decision
GAO denied the protest, ruling that:
- Aggregated References Were Allowed and Reasonable: ACLC argued that Linchpin’s past performance couldn’t match its own because none of Linchpin’s three references matched the full scope of the Performance Work Statement (PWS) on their own. GAO disagreed. The solicitation expressly allowed the agency to assess past performance “in the aggregate,” provided each reference had a “meaningful degree of relevance.” GAO found that standard was met in this case.
- Subcontractor Experience Was Fair Game: Linchpin’s references included two contracts performed by its proposed subcontractor. GAO reiterated that agencies are not required to discount subcontractor work in evaluating past performance magnitude or scope. There’s no rule that past performance credit is limited only to prime contractor efforts.
- Contracting Officer Can Use Personal Knowledge in Evaluation: GAO rejected ACLC’s argument that the contracting officer improperly relied on personal knowledge of Linchpin and its subcontractor. Citing long-standing precedent, GAO affirmed that evaluators may consider personal knowledge in assessing past performance, particularly when used to supplement the proposal record as it was here.
Key Takeaways for Contractors
- Incumbency Is Not a Trump Card: Being the incumbent may help, but agencies are not required to rate you higher if another offeror presents a strong, well-documented record.
- Subcontractor Past Performance Is Valid and Valuable: Agencies may credit subcontractor performance—and can even aggregate it across multiple references—as long as the work is relevant and aligned with the scope of the proposed effort.
- Personal Knowledge Is Allowed: Evaluators and contracting officers don’t have to pretend they’ve never worked with a contractor before. If used properly, personal knowledge can supplement the written record and support confidence ratings.
- Relevance Isn’t All-or-Nothing: GAO rejected the idea that every past performance reference must cover every task or subtask. Agencies have leeway to make holistic relevance determinations as long as they are documented and rational.