News & Analysis as of

Past Performance

Morrison & Foerster LLP - Government...

Bid Protest Roundup: Past Performance, Preliminary Injunctions, and Novel Regulatory Requirements

This month’s Bid Protest Roundup highlights two Court of Federal Claim decisions, addressing past performance and injunctive relief, and one by the U.S. Government Accountability Office (“GAO”), clarifying the applicability...more

Goodwin

FINRA Proposes to Add ‘Knowledgeable Employees’ to Category of Persons Who May Receive Projections and Targeted Returns Under Rule...

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This amendment builds on FINRA’s recent willingness to relax the prohibition on the use of projections and targeted returns in the marketing materials broker-dealers deliver to institutional investors and qualified...more

Morrison & Foerster LLP - Government...

September 2023 Bid Protest Roundup: Limits To Agency Discretion In Challenge To NAICS Code Assignments, Confines Of The...

This month’s Bid Protest Roundup focuses on a recent U.S. Court of Federal Claims decision involving the limitations of the government’s deference defense and a U.S. Government Accountability Office (GAO) that involved the...more

Goodwin

Blind Pool REIT IPOs: Real Estate Sponsors Are Getting Ready To Jump Back In

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Coming out of the Great Recession, there was a rush by real estate sponsors to raise “blind pool” capital to take advantage of displacement and distress in the real estate market. From 2009 through 2010, 30 new public real...more

PilieroMazza PLLC

Lapse in SAM Registration Disqualifies Government Contractor from Contract Award

PilieroMazza PLLC on

The Court of Federal Claims (COFC) recently interpreted FAR Clause 52.204-7, which requires offerors to register in the System for Award Management (SAM), to indicate that even a slight lapse in a contractor’s SAM...more

Womble Bond Dickinson

Government Accountability Office Determines Navy Improperly Evaluated Technical Proposal: Lewis Roca

Womble Bond Dickinson on

Bid protest determinations serve to resolve challenges to procurement decisions by government agencies. Beyond that purpose, these rulings can also offer valuable insights as to what factors determine whether or not a...more

Morrison & Foerster LLP - Government...

August 2022 Bid Protest Roundup: Affiliate Experience, JV Registration

In this month’s bid protest roundup, we consider: (1) an exception to the normal rule governing reliance on affiliate experience and past performance; and (2) two different bid protests of very similar solicitation terms that...more

Fox Rothschild LLP

Past Performance Upgrade for Small Businesses Results in Additional Compliance Requirement for Large Contractors

Fox Rothschild LLP on

A newly published Small Business Administration Final Rule provides small businesses with two new ways to satisfy Past Performance requirements when competing for federal prime contracts. The Rule takes effect on August 22,...more

Morrison & Foerster LLP - Government...

DECEMBER 2021 BID PROTEST ROUNDUP

This month’s Law360 Bid Protest Roundup focuses on two Government Accountability Office (GAO) decisions and one recent Federal Circuit decision. These decisions involve (1) the risks of using former government employees in...more

PilieroMazza PLLC

Past Performance: How to Use Yours, Benefit from Others’, and Defend It from Attacks

PilieroMazza PLLC on

You have undoubtedly heard the stories, a contractor with a flawless record going back years gets one bad past performance record, maybe due to themselves or a subcontractor, and now they are blackballed. While many in the...more

PilieroMazza PLLC

CIO-SP4 Is Ready To Launch: Is Your Business Equipped to Compete?

PilieroMazza PLLC on

CIO-SP4 may be one of the most significant opportunities for both small and large government contractors, particularly those in the healthcare space. The Coalition is pleased to host Cy Alba and Meghan Leemon of...more

PilieroMazza PLLC

[Webinar] Past Performance: How to Use Yours, Benefit from Others’, and Defend It from Attacks - January 20th, 2:00 pm - 3:00 pm...

PilieroMazza PLLC on

A government agency’s evaluation of an offeror’s past performance can often be the difference between winning or losing a government contract. And, for better or worse, agencies are given broad discretion in how they evaluate...more

Davis Wright Tremaine LLP

2021 NDAA Provides Increased Opportunities for Small Businesses to Establish Past Performance

The 2021 National Defense Authorization Act (NDAA) includes a significant change to how small businesses may establish past performance when bidding for prime contracts, greatly increasing the opportunity for small businesses...more

Foley & Lardner LLP

SEC Enforcement Actions Impacting Private Fund Advisers for Fiscal Year 2020

Foley & Lardner LLP on

On November 2, 2020, the SEC’s Division of Enforcement issued its 2020 Annual Report for the fiscal year ending September 30, 2020. While the Enforcement Division filed 405 standalone enforcement actions – the lowest total in...more

Vinson & Elkins LLP

[Webinar] Navigating Post-Covid Diligence Issues in M&A Transactions - September 24th, 10:00 am - 11:00 am CT

Vinson & Elkins LLP on

The COVID-19 pandemic and the accompanying market downturn have resulted in widespread uncertainty felt on a global scale – including in the M&A space. This webinar will explore ways M&A transactions – particularly due...more

PilieroMazza PLLC

[Webinar] Past Performance: How to Use Yours, Benefit from Others’, and Defend It from Attacks - June 8th, 2:00 pm - 3:00 pm ET

PilieroMazza PLLC on

A government agency’s evaluation of an offeror’s past performance can often be the difference between winning or losing a government contract. And, for better or worse, agencies are given broad discretion in how they evaluate...more

PilieroMazza PLLC

Past Performance: How to Use Yours, Benefit from Others’, and Defend It from Attacks

PilieroMazza PLLC on

A government agency’s evaluation of an offeror’s past performance can often be the difference between winning or losing a government contract. And, for better or worse, agencies are given broad discretion in how they evaluate...more

Stinson - Government Contracting Matters

Past Performance, Present (and Future) Problems

Government contractors should consider all contract performance vitally important because they can’t always control which past performance is considered by agency evaluators. ...more

PilieroMazza PLLC

[Webinar] CIO-SP4: A Virtual Town Hall Webinar - April 23rd, 2:00 pm - 3:00 pm ET

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CIO-SP4 may be one of the most significant opportunities for both small and large government contractors during 2020. Join Cy Alba of PilieroMazza and Reena Bhatia of ProposalHelper as they discuss the potential impacts of...more

Sheppard Mullin Richter & Hampton LLP

Top 10 Provisions of CMS Proposed Rule: Medicare Advantage and Part D Programs for CY2021 and CY2022

As promised, here is a summary of some key provisions in CMS’ proposed rule relating to the Medicare Advantage and Part D programs for contract years 2021 and 2022. CMS is soliciting comments on a number of issues and we urge...more

Bradley Arant Boult Cummings LLP

Can You Challenge a CPAR Evaluation in a Bid Protest?

Technically, no. However, when the contractor is protesting the award of a contract for the same agency that issued the unfavorable Contractor Performance Evaluation Report (CPAR), the contractor may have some success arguing...more

Stinson - Government Contracting Matters

Don’t Rely on a Procuring Agency to Track Down Past Performance Questionnaires

Given how much emphasis federal procurement law properly places on fairness, it can be easy to assume that government buyers must do everything necessary to ensure a fair procurement....more

PilieroMazza PLLC

Performance Anxiety: Five Questions from Government Contractors on Past Performance

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A government contractor’s past performance can spell the difference between proposal rejection and contract award, and agencies are given broad discretion in how they evaluate past performance. It is critical that companies...more

Sheppard Mullin Richter & Hampton LLP

R.I.P. PPIRS

First things first, I’m sorry about the title; I couldn’t resist. The longer, alternate title would have been “Rest In Peace – the Past Performance Information Retrieval System Sleeps with the Fishes.” But that doesn’t have...more

Williams Mullen

PODCAST: Challenging Negative CPARS Reports – Protecting Contractor Reputation Through CPARS Challenges

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In this episode of Williams Mullen's GovCon Perspectives, Tony Anikeeff discusses CPARS reports and explains why they are a fundamental element of a contracting officer’s evaluation of past performance in considering...more

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