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GAO Backs Agency’s Broad View of Relevance in Past Performance Evaluation

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In SRM Group, LLC, B-423695 (Sept. 25, 2025​), SRM Group, the incumbent contractor, protested the Army’s award of a contract for lodging and transportation services at Camp Robinson to BryMak & Associates. SRM argued that the agency’s past performance evaluation was flawed and that the resulting best-value tradeoff was unreasonable. At the heart of the protest was SRM’s claim that BryMak’s past performance references did not merit the same “substantial confidence” rating that SRM received. SRM challenged the relevance of BryMak’s references, the inclusion of a subcontractor’s limited experience and the agency’s treatment of SRM’s own incumbent performance. GAO rejected each of these arguments, finding the evaluation well-documented and consistent with the solicitation.

The Decision
The GAO denied the protest, ruling that:

  1. Relevance Was Not Limited to the Solicitation’s NAICS Code: SRM argued that two of BryMak’s past performance contracts were not “very relevant” because they were performed under NAICS code 561720 (janitorial services) rather than the NAICS code 561210 (facility support services) listed in the solicitation. GAO rejected this argument, noting that the solicitation defined relevant past performance as “services similar to those required by the RFP’s NAICS code,” not that they must be performed under that specific code.
  2. Short Performance Period Did Not Disqualify Subcontractor Reference: SRM objected to the agency’s crediting of one subcontractor’s contract, which had only been underway for three weeks at the time proposals were due. GAO found no error, pointing to the agency’s reliance on broader CPARS data and its holistic consideration of all of BryMak’s references, including substantial quality assessments across multiple contracts​.
  3. No Requirement That Each Reference Cover the Entire Scope: GAO also rejected SRM’s implication that each past performance reference must mirror the entire scope of the current requirement. Where the solicitation does not specifically define what scope or magnitude must be matched, agencies have discretion to assess relevance. Here, the agency reasonably found that BryMak’s references, while diverse, addressed the core aspects of the required services.
  4. Incumbency Does Not Guarantee the Highest Rating: SRM argued that its incumbent contract—the only one supported by CPARS quality data—should have been given greater weight and that it deserved a higher rating than BryMak. GAO reiterated that an offeror’s status as incumbent does not entitle it to higher ratings or preferential treatment. The agency reasonably viewed both SRM’s and BryMak’s past performance as demonstrating a high likelihood of success.

Key Takeaways for Contractors

  1. Relevance Is About Similarity, Not NAICS Code Matching: Agencies are not required to base past performance relevance on matching NAICS codes. The actual scope, magnitude and services performed matter more than the technical classification.
  2. Short-Term Work Can Still Be Very Relevant: Even recently initiated contracts may be considered in past performance evaluations, especially when combined with broader CPARS data that shows consistent quality. Contractors should keep this in mind when deciding what work should be used as a reference.
  3. Each Reference Contract Does Not Have to Do It All: Unless a solicitation says otherwise, past performance references may be evaluated as part of an overall picture. They do not each need to match the entire scope of the new contract.
  4. Being the Incumbent 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 past performance record.