BNUMBER: B-274315.2
DATE: October 18, 1996
TITLE: El Paso Analytics, Inc.--Entitlement to Costs
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Matter of:El Paso Analytics, Inc.--Entitlement to Costs
File: B-274315.2
Date:October 18, 1996
Thomas L. McGovern III, Esq., and S. Gregg Kunzi, Esq., Hogan &
Hartson L.L.P, for the protester.
Jerold D. Cohen, Esq., Office of the General Counsel, GAO,
participated in the preparation of the decision.
DIGEST
Contracting agency terminated delivery order issued under a small
disadvantaged business's section 8(a) contract 3 weeks after another
section 8(a) firm protested that the order was outside the contract's
scope and denied the protester the chance to compete for the work.
Protester is not entitled to protest costs notwithstanding its section
8(a) status since the General Accounting Office's concern with respect
to entitlement claims is whether the contracting agency reacted
quickly in response to a protest filing to review its actions and
correct an impropriety, and in this case corrective action was taken
promptly, early in the protest process.
DECISION
El Paso Analytics, Inc. requests that our Office recommend the payment
of El Paso's costs of filing and pursuing its protest of the award of
a delivery order to Innovative Logistics Techniques, Inc. (Innolog)
under contract No. DAAB07-95-D-H004 with the Army's
Communications-Electronics Command (CECOM).
We deny the request.
El Paso protested the delivery order, which was for warehousing,
maintenance, and inventory services, as being outside the scope of
Innolog's contract on August 23, 1996. On September 12 the agency
terminated the order and asked that we therefore dismiss the protest
as academic, which we did on September 20.
Our Bid Protest Regulations, sec. 21.8(e), 61 Fed. Reg. 39039, 39046
(1996) (to be codified at 4 C.F.R. sec. 21.8(e)), provide that we may
recommend that an agency pay protest costs, including attorneys' fees,
where the agency decides to take corrective action in response to a
protest. El Paso argues that even though CECOM corrected its
procurement error soon after El Paso protested, El Paso is entitled to
costs both because the protest was clearly meritorious, and based on
"special circumstances":
"This protest involved CECOM's improper manipulation and
avoidance of procurement regulations designed specifically to
benefit small disadvantaged businesses. El Paso is a small
disadvantaged business
. . . . There are compelling policy reasons why an agency should
be held to a stricter standard in assessing the timeliness of
corrective action where the procurement impropriety arises from
an improper attempt to avoid regulations aimed at assisting small
disadvantaged businesses. . . ."
A decision whether to award costs in a particular case is based
primarily on where in the protest process the decision to take
corrective action was made and communicated. See Pulse Electronics,
Inc.--Request for Declaration of Entitlement to Costs, B-243625.3,
Aug. 30, 1991, 91-2 CPD para. 222. Our Regulations do not envision the
payment of costs in every circumstance; rather, the provision was
adopted to encourage agencies to take corrective action in a
reasonably prompt fashion. Thus, we will recommend payment of protest
costs only where the agency unduly delayed taking corrective action in
the face of a clearly meritorious protest. See Diez Management Sys.,
Inc.--Entitlement to Costs, B-250831.3, Apr. 13, 1993, 93-1 CPD para. 313.
In its protest El Paso stated that the delivery order work added to
Innolog's section 8(a)[1] contract--which El Paso termed an
"'omnibus' indefinite delivery support contract" for technical
services--had been the subject of El Paso's own expiring 8(a) contract
with CECOM. El Paso's protest basis was that the added work was
outside the scope of Innolog's contract, and that CECOM's action
improperly denied El Paso the opportunity to compete for it or to be
considered for a sole-source 8(a) award to continue its performance.
Notwithstanding El Paso's point that in determining protest cost
entitlement an agency's procurement error should be viewed
particularly critically where small disadvantaged businesses are
involved, our concern with respect to entitlement claims is, as stated
above, whether the contracting agency reacted quickly in response to a
protest filing to review its actions and correct an impropriety.
Here, the agency terminated the protested delivery order 3 weeks after
the protest was filed. Such corrective action, taken early in the
protest process, is precisely the kind of prompt reaction to a protest
that our Regulations are designed to encourage. See Special Sys.
Servs., Inc.--Entitlement to Costs, B-252210.2, June 8, 1993, 93-1 CPD para.
445.
El Paso's request is denied.
Comptroller General
of the United States
1. Section 8(a) of the Small Business Act, 15 U.S.C. sec. 637(a) (1994),
authorizes the Small Business Administration to enter into contracts
with government agencies and arrange for the performance of the
contracts by letting subcontracts to socially and economically
disadvantaged small business concerns.