TITLE: B-299548.2, Paragon Systems, Inc., September 10, 2007
BNUMBER: B-299548.2
DATE: September 10, 2007
*****************************************************
B-299548.2, Paragon Systems, Inc., September 10, 2007

   DOCUMENT FOR PUBLIC RELEASE
   The decision issued on the date below was subject to a GAO Protective
   Order. This redacted version has been approved for public release.

   Decision

   Matter of: Paragon Systems, Inc.

   File: B-299548.2

   Date: September 10, 2007

   Katherine S. Nucci, Esq., and Timothy Sullivan, Esq., Thompson Coburn LLP,
   for the protester.

   Richard J. Sprunk, Esq., Department of Homeland Security, for the agency.

   Louis A. Chiarella, Esq., and Christine S. Melody, Esq., Office of the
   General Counsel, GAO, participated in the preparation of the decision.

   DIGEST

   1. Agency's evaluation of vendor's past performance was reasonable where
   agency contacted an individual who was familiar with the vendor's
   performance, even though the individual was not the point of contact
   designated by the vendor in its past performance reference.

   2. Protester's contention that agency past performance evaluation was
   unreasonable because the agency did not distinguish between degrees of
   relevance in evaluating each vendor's past performance is denied where the
   evaluation was reasonable, and consistent with the stated evaluation
   criteria; there is no per se requirement that an agency weight differently
   the ratings given each vendor based on an assessment of the relative
   relevance of the vendor's prior contracts.

   DECISION

   Paragon Systems, Inc. protests the issuance of a task order to NCLN20,
   Inc. pursuant to request for quotations (RFQ) No. 186419, issued by the
   Federal Protective Service (FPS), Immigration and Customs Enforcement,
   Department of Homeland Security (DHS), for armed security guard services
   at federal facilities located throughout the state of Arizona.[1] Paragon
   argues that the agency misevaluated vendors' quotations in the area of
   past performance.

   We deny the protest.

   BACKGROUND

   The RFQ, issued on December 8, 2006, to holders of General Services
   Administration (GSA) Federal Supply Schedule (FSS) contracts for guard
   services, contemplated the issuance of a time-and-materials task order for
   a base year together with four 1-year options.[2] The solicitation, which
   included a statement of work (SOW) and instructions to vendors regarding
   the submission of quotations, established three evaluation criteria:
   mission capability; past performance; and price.[3] The mission capability
   and past performance evaluation criteria were of equal importance and,
   when combined, were significantly more important than price. The RFQ
   stated that the agency would select the vendor whose quotation was
   determined to represent the "best value" to the government, all factors
   considered. RFQ at 3-5.

   With regard to past performance, the RFQ stated that a vendor's quotation
   "should provide a summary of [its] most recent, related, relevant efforts
   during the last three (3) years that demonstrate [its] potential for
   success on this effort. Submit a maximum of three references using the
   forms/format provided herein."[4] Id. at 2. Regarding the agency's
   evaluation of vendors' past performance the RFQ stated:

     The Government will evaluate the past performance data submitted for
     recency, relevancy, and quality. Relevancy of past performance data will
     be determined by considering performance on contracts of a similar
     nature, size, scope, dynamic environment, and complexity, utilizing a
     comparable number of personnel with like skills. Some past performance
     data may be considered more relevant to this acquisition than other
     data. The Government reserves the right to consider any other
     information obtained through other means including those from Government
     and commercial sources.[5]

   Id. at 4.

   Eleven vendors, including Paragon and NCLN20, submitted quotations by the
   January 24, 2007 closing date. Paragon's quotation included three past
   performance references. These were: (1) its armed guard security services
   contract for the Social Security Administration headquarters in Baltimore,
   Maryland (220 guards at one location); 2) its statewide armed guard
   security services contract with FPS for Alabama (150 guards at over 50
   locations); and (3) its statewide armed guard security services contract
   with FPS for Kentucky (120 guards at nearly 50 locations). AR, Tab 3,
   Paragon's Quotation, Vol. II, Past Performance Proposal, at 7-9. By
   comparison, the SOW here required the contractor to provide approximately
   100 security guards at 30 separate locations. AR, July 2, 2007, at 5;
   Protest, June 4, 2007, at 8.

   NCLN20's quotation also included three past performance references
   regarding its own performance.[6] These were: (1) its armed guard security
   services contract with FPS for Northern and Central California (100-105
   guards at more than 25 locations); (2) its armed guard security services
   efforts for the Social Security Administration's Western Regional
   Processing Center in Richmond, California (30-35 guards at one location);
   and (3) its armed guard security services efforts for the Bureau of
   Reclamation at the Folsom Dam, Folsom, California (10-12 guards at one
   location). AR, Tab 2, NCLN20's Quotation, Vol. II, Past Performance
   Proposal, at 6-8, 22-25.

   An agency technical evaluation team (TET) evaluated vendors' quotations
   using the adjectival rating system set forth in the RFQ. The TET's
   evaluation ratings of Paragon and NCLN20 were as follows:

   +--------------------------------------------------------+
   |Factor                |    Paragon    |     NCLN20      |
   |----------------------+---------------+-----------------|
   |Mission Capability    |     Meets     |      Meets      |
   |----------------------+---------------+-----------------|
   |Past Performance      | Satisfactory  |  Satisfactory   |
   |----------------------+---------------+-----------------|
   |Price                 |  $28,024,497  | $27,137,559[7]  |
   +--------------------------------------------------------+

   Id., Tab 4, TET Report, at 3, 6. Based on the TET's evaluation, the source
   selection authority (SSA) concluded that the NCLN20's quotation was the
   lowest-priced among those deemed technically equal and, on that basis,
   selected NCLN20. Id., Tab 5, Source Selection Decision, at 4.

   On March 13, Paragon filed a protest with our Office asserting that the
   agency's evaluation of vendors' quotations, including the evaluation of
   past performance, was unreasonable and had resulted in an improper
   selection decision. By letter to our Office dated March 15, DHS provided
   notice that it was taking corrective action in response to Paragon's
   protest by reevaluating vendors' quotations. Based on the agency's
   announced corrective action, our Office dismissed Paragon's March 13
   protest.

   As part of its revised evaluation, the TET contacted all three of
   Paragon's past performance references.[8] Paragon's Social Security
   Administration contract reference considered Paragon's performance to be
   excellent and stated that he would use the firm again without hesitation.
   With regard to Paragon's FPS contract for Alabama, the reference stated
   that while the contractor had performed well overall, a few performance
   problems had been brought to Paragon's attention and had not been fixed;
   the reference also opined that he would award another contract to Paragon
   if a few things changed. For Paragon's FPS contract for Kentucky, the
   reference stated that Paragon had been generally consistent in manning all
   required posts, it adapted to changes quickly and smoothly, and its
   supervision of personnel was satisfactory for the most part. The same
   reference, however, also noted various shortcomings in Paragon's
   performance.[9] AR, Tab 10, Revised TET Report, at 3; Tab 9, Paragon's
   Past Performance References, at 1-2, 8-9, 13-15. The TET considered all of
   Paragon's past performance references to be recent and relevant, and,
   based on the information received, concluded that Paragon's overall past
   performance was satisfactory. Id., Tab 10, Revised TET Report, at 3.

   The TET also contacted NCLN20's past performance references as part of its
   reevaluation of vendors' quotations. For NCLN20's FPS contract, the TET
   obtained the reference from the contract's program manager (PM), who
   stated that the contractor's performance was problematic, its cost control
   questionable, and that there had been some difficulty in the ongoing
   transition from NCLN20 to the new contractor.[10] Id. at 2. The TET
   considered this reference to be both recent and relevant. With regard to
   NLCN20's Social Security Administration effort, the reference stated that
   there had been no performance problems and found the contractor was very
   responsive to changes in the agency's requirements. The reference here
   also stated that NCLN20 supervised its employees very well and was very
   organized, and that she would award another contract to the firm. The TET
   found NCLN20's second reference to be recent, but because it was for a
   single building location, considered it not as relevant as the vendor's
   first reference. Multiple attempts by the TET to contact NCLN20's third
   reference (the Bureau of Reclamation) were unsuccessful. The TET concluded
   that while NCLN20 had recent and relevant experience, based on the
   information received, the vendor's past performance merited an overall
   rating of unsatisfactory. Id., Tab 10, Revised TET Report, at 2; Tab 8,
   NCLN20's Past Performance References, at 14, 24.

   The TET's final revised ratings for Paragon and NCLN20 were as follows:

   +------------------------------------------------------+
   |Factor               |    Paragon    |     NCLN20     |
   |---------------------+---------------+----------------|
   |Mission Capability   |     Meets     |     Meets      |
   |---------------------+---------------+----------------|
   |Past Performance     | Satisfactory  | Unsatisfactory |
   |---------------------+---------------+----------------|
   |Price                |  $26,156,096  |  $25,625,518   |
   +------------------------------------------------------+

   Id., Tab 11, Revised TET Report Summary Chart; Tab 13, Revised Source
   Selection Decision, at 1.

   The SSA recognized, after receipt of the TET's revised evaluation report,
   that the change in NCLN20's past performance rating from satisfactory to
   unsatisfactory was the result of the reference provided by the PM for the
   vendor's FPS contract, an individual with whom the SSA was familiar.[11]
   Additionally, based on DHS's recent award of separate follow-on security
   guard service contracts for the Northern and Central California areas, and
   the internal review that followed the negative references for NCLN20
   provided by the PM on those occasions, the SSA was also aware that the
   contract file here contained no documentation to substantiate the PM's
   claims of poor performance.[12] Further, the written comments furnished by
   the PM did not address many of the areas of inquiry contained in the past
   performance questionnaire, and much of the information that the PM did
   provide was deemed by the SSA to be irrelevant to the issue of NCLN20's
   past performance. AR, Tab 13, Revised Source Selection Decision, at 5.

   Based on the foregoing information, and the fact that NCLN20's second
   reference had indicated there had been no problems with the vendor's
   performance, the SSA decided to seek additional information regarding
   NCLN20's past performance. Specifically, the SSA contacted the contract
   specialist responsible for administering NCLN20's FPS contract, who had
   been involved with the contract since its inception (5  1/2 years
   earlier). The contract specialist provided a reference stating that
   NCLN20's performance level was very satisfactory, that the contractor was
   very responsive to both contracting agency and customer concerns, and that
   its response to changes in government requirements was very good. Id., Tab
   12, Supplementary NCLN20 Past Performance Reference. Based on this
   additional reference, information obtained orally from other agency
   personnel administering NCLN20's active FPS contracts, and her personal
   knowledge of the vendor's current performance, the SSA concluded that
   NCLN20's past performance rating should be raised to satisfactory. Id.,
   Tab 13, Revised Source Selection Decision, at 5; Contracting Officer's
   Statement at 4-5.

   The SSA subsequently concluded that the NCLN20's quotation was again the
   lowest-priced among those determined technically equal and, on that basis,
   selected NCLN20 for award. Id., Tab 13, Revised Source Selection Decision,
   at 6. This protest followed.

   DISCUSSION

   Paragon's protest raises numerous issues regarding the agency's evaluation
   of both its and NCLN20's past performance. Although we do not here
   specifically address all of the protester's arguments, we have fully
   considered all of them and find that they afford no basis to sustain the
   protest of the selection decision here.

   Paragon first protests that DHS improperly contacted the wrong reference
   for the vendor's two FPS contracts. Both of Paragon's FPS contracts were
   handled by the same contracting officer. Prior to the agency's
   reevaluation of quotations, Paragon updated the point of contact
   information for its FPS contracts, as there had been a change in
   contracting officers. Paragon contends that notwithstanding this change,
   DHS still contacted the former contracting officer for purposes of
   obtaining past performance references for Paragon.[13] Paragon contends
   that the current contracting officer (or the contracting officer's
   technical representative (COTR)) was in the best position to provide
   current and relevant information about Paragon's performance, not the
   former contracting officer, an individual who had been involved with
   Paragon's CDA claims. Had DHS contacted the correct reference for these
   FPS contracts, the protester argues, Paragon would have received a past
   performance rating of very good. Protest, June 4, 2007, at 5-7.

   When, as here, an agency conducts a formal competition under the FSS
   program for the issuance of a task order, we will review the agency's
   actions to ensure that the evaluation was reasonable and consistent with
   the solicitation and applicable procurement statutes and regulations.
   Worldwide Language Res., Inc., B-297210 et al., Nov. 28, 2005, 2005 CPD
   para. 211 at 3; COMARK Fed. Sys., B-278343, B-278343.2, Jan. 20, 1998,
   98-1 CPD para. 34 at 4-5. Where a solicitation contemplates the evaluation
   of vendors' past performance, the agency has the discretion to determine
   the scope of the performance history to be considered, provided all
   quotations are evaluated on the same basis and the evaluation is
   consistent with the terms of the solicitation. See Weidlinger Assocs.,
   Inc., B-299433, B-299433.2, May 7, 2007, 2007 CPD para. 91 at 8. In this
   regard, an agency is generally not precluded from considering any relevant
   past performance information, regardless of its source. See, e.g., NVT
   Techs., Inc., B-297524, B-297524.2, Feb. 2, 2006, 2006 CPD para. 36 at 5.
   Regarding the relative merits of vendors' past performance information,
   this matter is generally within the broad discretion of the contracting
   agency, and our Office will not substitute our judgment for that of the
   agency. See, e.g., Clean Harbors Envtl. Servs., Inc., B-296176.2, Dec. 9,
   2005, 2005 CPD para. 222 at 3. A protester's mere disagreement with the
   agency's judgment does not establish that an evaluation was improper. Id.

   As a preliminary matter, the record here shows that DHS obtained the past
   performance reference for Paragon's FPS contract for Alabama not from the
   former contracting officer, but from the COTR--see AR, Tab 9, Paragon's
   Past Performance References, at 8-9--an individual who Paragon itself
   describes as being "in the best position to provide current and relevant
   information about Paragon's performance." Protest, June 4, 2007, at 7.
   With regard to Paragon's FPS contract for Kentucky, while the record
   indicates that the agency did obtain the past performance reference from
   the former contracting officer, id. at 13-16, we find Paragon's challenge
   on this ground to be without merit. As discussed above, an agency is
   generally not precluded from considering any relevant information, and is
   not limited to considering only the information provided within the "four
   corners" of vendor's quotation when evaluating past performance.[14] See
   FAR sect. 15.305(a)(2)(ii); Weidlinger Assocs., Inc., supra; Forest
   Regeneration Servs. LLC, B-290998, Oct. 30, 2002, 2002 CPD para. 187 at 6.
   Likewise, there exists no requirement mandating that an agency contact the
   specific individual designated by the vendor as the reference when seeking
   past performance information. Rather, the relevant inquiry as to who may
   furnish a past performance reference is whether the individual has a
   sufficient basis of knowledge to render an informed opinion regarding the
   vendor's prior work efforts.

   Paragon does not argue that the former contracting officer for its FPS
   contracts did not have a sufficient basis of knowledge to render an
   informed opinion regarding Paragon's performance. In fact, the protester
   admits that the former contracting officer was involved with Paragon's FPS
   contracts for the past 3 years, while the current contracting officer had
   only been in that position for less than 1 month at the time the agency
   sought the past performance references here. Protest, June 4, 2007, at 7.
   Based on our review of the record we find nothing unreasonable in the
   agency's evaluation of Paragon's quotation with regard to past
   performance. As noted above, DHS obtained and considered the input
   furnished by individuals familiar with Paragon's performance for each of
   the contract references that Paragon included in its quotation. The agency
   reasonably determined that Paragon's references were all recent and
   relevant, and based on the information received, warranted an overall past
   performance rating of satisfactory. To the extent that Paragon argues that
   the reference comments were inaccurate and unfounded, see Comments, July
   12, 2007, at 13, we conclude that this represents mere disagreement with
   the agency's judgment.[15]

   Paragon also protests the agency's evaluation of NCLN20's past
   performance, specifically the SSA's determination to raise NCLN20's past
   performance rating from unsatisfactory to satisfactory. We find the
   protester's assertions here to be without merit.

   As set forth above, the SSA was aware of various allegations regarding the
   PM that caused the SSA to question her judgment. As a result, the SSA
   decided to seek additional references regarding NCLN20's performance on
   its FPS contract. The record does not reflect, as the protester contends,
   that the SSA completely discounted the PM's reference and replaced it with
   that provided by the FPS contract specialist. Rather, the record indicates
   that the SSA properly considered all the sources of information she had
   regarding NCLN20's past performance.

   Paragon also argues that the agency's evaluation of NCLN20's past
   performance was unreasonable because the SSA did not consider all the
   information which the agency possessed regarding the awardee's
   performance. Specifically, the protester contends that the reference
   furnished by the PM regarding NCLN20's FPS contract contained the comments
   of two agency inspectors that also were critical of the awardee's past
   performance. These additional comments, the protester asserts, were known
   to the TET but were not made part of the evaluation record and were not
   considered by the SSA. Paragon argues that the information here was "too
   close at hand" to be ignored, and had the SSA considered these additional
   adverse comments regarding the awardee's past performance, NCLN20 would
   not have received a past performance rating of satisfactory. Comments,
   July 19, 2007, at 1-2, Comments, July 20, 2007, at 1-2.

   As set forth above, the PM provided the TET with the original reference
   regarding NCLN20's FPS contract. Together with her own comments, the PM
   also attached comments from two agency inspectors. AR, Tab 8, NCLN20's
   Past Performance References, at 16. The inspectors' comments were not
   prepared as a reference regarding NCLN20's performance on its FPS
   contract. Rather, the comments were prepared as part of the evaluation of
   quotations from various vendors, including NCLN20, for the follow-on FPS
   contract for the Northern California area.[16] Id., Tab 25, Evaluation
   Comments of C.F.; Tab 26, Evaluation Comments of O.L. According to the
   agency, the inspectors' comments were subsequently lost and were not part
   of the evaluation file provided to the SSA. Given that the relevance and
   the context of the comments is at best unclear, and in fact the comments
   apparently were not considered material by the TET itself even to bolster
   its unsatisfactory rating of the awardee, in our view the fact that this
   information was not presented to the SSA does not affect the
   reasonableness of her evaluation of NCLN20's past performance.

   Paragon also argues that the agency failed to adequately consider the
   comparative relevance of the vendors' past performance, citing our
   decision in Clean Harbors Envtl. Servs., Inc., supra. The protester
   alleges that its past performance references were substantially more
   relevant than those of NCLN20 and therefore it was improper for the agency
   to give the vendors equal ratings. We disagree.

   Our decision in Clean Harbors is inapposite to the circumstances here. In
   Clean Harbors, the agency entirely failed to consider the relevance of
   offerors' past performance references as part of its determination of
   relative equality. By contrast, the record here clearly shows that the
   agency properly took into account the relevance of each contract reference
   as part of its evaluation of quotations. For example, the TET expressly
   concluded that NCLN20's FPS contract was relevant here, and recognized
   that NCLN20's Social Security Administration reference, being smaller in
   both size and scope, was not as relevant as the firm's FPS contract to the
   SOW requirements here.[17] AR, Tab 10, Revised TET Report, at 2. Here, the
   agency looked at the relevance of each vendor's past performance and
   reasonably concluded each vendor's past performance merited a satisfactory
   rating. To the extent that Paragon argues that it had more (either
   quantitatively or qualitatively) relevant references than NCLN20, this
   constitutes mere disagreement with the agency's reasonable judgment that
   NCLN20 had relevant past performance. See Birdwell Bros. Painting &
   Refinishing, B-285035, July 5, 2000, 2000 CPD para. 129 at 5. There is
   simply no requirement that vendors have an equivalent number of relevant
   references in order to receive equal ratings.[18]

   The protest is denied.

   Gary L. Kepplinger
   General Counsel

   ------------------------

   [1] The electronic announcement of the solicitation here was termed an
   RFQ, Agency Report (AR), July 2, 2007, at 2 n.1, and the responding
   vendors referred to the solicitation as an RFQ, although the solicitation
   itself was identified as a request for proposals and stated throughout
   that "offerors" were to submit "proposals." These discrepancies are not
   relevant to our analysis in this decision. For purposes of consistency, we
   will refer to the solicitation as an RFQ, the responding firms as vendors,
   and the responses to the solicitation as quotations.

   [2] The agency subsequently revised the base performance period to reflect
   only the unfinished portion of fiscal year 2007. See AR, Tab 5, Source
   Selection Decision, at 1 (base period of Apr. 1--Sept. 30, 2007), Tab 13,
   Revised Source Selection Decision, at 1 (base period of July 1--Sept. 30,
   2007).

   [3] The mission capability evaluation factor was in turn comprised of four
   equal subfactors, not relevant to the protest here.

   [4] The RFQ included past performance reference worksheets that vendors
   were to complete and return as part of their quotations. The worksheets
   required, among other things, the contract number, the name, address, and
   phone number of the contracting activity, the period of performance, the
   name and phone number of the contracting officer (or equivalent), and the
   name and phone number of the program manager (or equivalent). Id., attach.
   4, Past Performance Reference Worksheet.

   [5] The RFQ also advised vendors of the agency's planned evaluation rating
   scheme. With regard to the mission capability factor and subfactors,
   quotations were to be rated as either "Exceeds," "Meets," or "Does Not
   Meet." Id. at 3. The solicitation stated that vendors' past performance
   would be evaluated as either "Very Good (Significant Confidence),"
   "Satisfactory (Confidence)," "Neutral (Unknown Confidence)," or
   "Unsatisfactory (No Confidence)," and included definitions for each of
   these adjectival ratings. Id. at 5.

   [6] NCLN20's quotation also contained three past performance references
   for its primary subcontractor, AlliedBarton Security Services LLC. AR, Tab
   2, NCLN20's Quotation, Vol. II, Past Performance Proposal, at 10-12. In
   its report to our Office, the agency stated that "[i]t was determined that
   the past performance information for NCLN20 was sufficient to stand on its
   own merit, thus AlliedBarton's performance information was not considered
   during the evaluation." Contracting Officer's Statement at 3.

   [7] The TET also found the quotations of three other vendors to be
   technically equal to those of Paragon and NCLN20; all were higher priced
   than Paragon's quotation. Id., Tab 5, Source Selection Decision, at 1,
   3-4.

   [8] The TET utilized a written questionnaire consisting of eight specific
   inquiries as part of its evaluation of vendors' past performance. The past
   performance references either completed the questionnaire themselves, or a
   TET member filled out the questionnaire based on a telephonic interview of
   the reference.

   [9] The reference found that problem-solving was one of the contractor's
   weak areas; that there seemed to be unwillingness on Paragon's part to
   deal with issues because of the employees' union; potential personnel
   problems had lingered, causing new ones to arise; the contractor seemed to
   change managers about every 6 months which led to different and sometimes
   conflicting directions; and Paragon had not had an administrative
   specialist or dedicated person to help manage the day-to-day paperwork but
   had relied on a lead supervisor and contract manager. AR, Tab 9, Paragon's
   Past Performance References, at 13-15.

   [10] In her actual written comments, the PM stated that NCLN20 had
   falsified a past performance document by altering information contained
   therein (e.g., the contract's total amount/value), questioned the vendor's
   management and financial depth (NCLN20 had informed its employees of the
   intended use of pension funds in order to meet payroll), and found that
   the vendor had failed to maintain proper guard records. Id., Tab 8,
   NCLN20's Past Performance References, at 14.

   [11] The SSA was aware of allegations that the PM was believed to be
   romantically involved with an employee of the contractor for which she had
   program oversight, an allegation that caused the SSA to question the PM's
   judgment. The SSA also knew that the PM's performance as a program manager
   had been less than successful, and that she had been placed on an employee
   performance improvement plan by her supervisor. Contracting Officer's
   Statement at 4; AR, Tab 24, Internal Agency Emails, Feb. 26-27, 2007.

   [12] Specifically, "there was no indication in any of the contract files
   of negative performance issues noted by the contracting officer. Option
   years [had also been] exercised, an indication that NCLN20's performance
   was satisfactory or better." Contracting Officer's Statement at 4. The few
   quarterly performance reviews that had been done also indicated the
   contractor's performance had been satisfactory or better. Id., AR, Tab 14,
   NCLN20 Quarterly Evaluation Reports for Contract No. GS-09P-01-NZD-0005.

   [13] Paragon also contends that the former FPS contracting officer had
   been involved with Contract Disputes Act (CDA) appeals that Paragon
   successfully pursued under both contracts. Protest, June 4, 2007, at 5-7.

   [14] Further, the solicitation here also expressly permitted the agency to
   consider past performance information obtained from sources other than the
   vendors' quotations. RFQ at 4.

   [15] Paragon also provides no evidence to support its assertion that the
   former FPS contracting officer was not objective, and inferences of bad
   faith or bias do not rise to the level of proof required to demonstrate
   that an agency employee was biased against it. TPL, Inc., B-297136.10,
   B-297136.11, June 29, 2006, 2006 CPD para. 104 at 21.

   [16] Regarding NCLN20's proposal, one inspector stated, "Past Performance
   - Fails to meet. Performance References: description of current contract
   services provided [does] not accurately reflect duties performed. I have
   professional knowledge of site & contract references," while the other
   inspector stated, "Past Performance - Fails to meet (previous history of
   slow to respond to employees unacceptable behavior, lack of sufficient
   reserve pool, lack of professionalism of training officer, FPS routinely
   not being made aware of abandoned post)." Id., Tab 25, Evaluation Comments
   of C.F., at 1; Tab 26, Evaluation Comments of O.L., at 1. We note that,
   with regard to the first inspector, the conclusion here is unsupported:
   while characterizing NCLN20's past performance as unsatisfactory, the
   supporting comments lack any meaningful explanation.

   [17] Moreover, the agency was not precluded from relying upon, or giving
   weight to, NCLN20's Social Security Administration reference merely
   because it was determined to be less relevant. There is no requirement
   that an agency apply a "mathematical calculation" to the combined
   relevance and quality of a vendor's reference as part of its past
   performance evaluation. Weidlinger Assocs., Inc., supra; University
   Research Co., LLC, B-294358.6, B-294358.7, Apr. 20, 2005, 2005 CPD para.
   83 at 16 (holding that there is no per se requirement that an agency
   weight differently the ratings given offerors based on an assessment of
   the relative relevance of the offerors' prior contracts).

   [18] Paragon argues that the information provided by the PM questioning
   NCLN20's integrity and business ethics should have been taken into account
   by the agency as part of its responsibility determination of the awardee.
   Comments, July 12, 2007, at 8-11. Assuming if we were to agree with
   Paragon that there are legitimate issues concerning NCLN20's integrity and
   ethics, we have previously determined that there is no requirement that an
   ordering agency perform a responsibility determination when, as here,
   placing a task or delivery order under an FSS contract; the initial
   responsibility determination made by GSA in connection with the award of
   the underlying FSS contract satisfies the requirement for a responsibility
   determination regarding that offeror, and there is no requirement that an
   ordering agency perform additional responsibility determinations when
   placing orders under that contract. Advanced Tech. Sys., Inc., B-296493.6.
   Oct. 6, 2006, 2006 CPD para. 151 at 5-6.