Can past performance be used as a sub-factor to a proposal's technical evaluation or should it be separated as a stand alone evaluation factor?
In order to establish a basis for the response to your question I offer the following three paraphrased definitions:
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1) Evaluation factors and significant sub-factors - the factors used by the government in a competitive request for proposal to make a contract award decision (FAR 15.304(a)). These factors and sub-factors represent the specific characteristics that are tied to significant RFP requirements and objectives that have an impact on the source selection decision and are expected to be discriminators. The factors are the baseline against which an offeror's proposal is evaluated in order to make a best value decision.
2) Technical factor(s) - refers to non-cost factors other than past performance. The purpose of the technical factors is to assess the offeror's proposed approach to satisfy the Government's requirements.
3) Past performance - DPAP memo, dated 04 march 2011, paragraph 22.214.171.124.2, an evaluation factor that assesses the degree of confidence the Government has in an offeror's ability...based on a demonstrated record of performance.
In addition to FAR 15.304, DFARS 215.304, and PGI 215.304, the most recent policy issued concerning evaluation factors in contained in DPAP memo, dated 04 March 2011, entitled, Department of Defense Source Selection Procedures. To understand the relationship of evaluation factors to the complete source selection process, the entire memo must be read and considered. Individual paragraphs should not be taken out of context. Paragraph 2.3, "Develop the Request for Proposal" contains information directly related to evaluation factors, including past performance. Past performance evaluation guidance is also provided in the same memo, paragraph 126.96.36.199, to include Table 4. Relevancy Ratings.
A review of the FAR/DFARS/PGI and the DPAP memo, only refers to "past performance" as a stand-alone evaluation factor to include a separate Table for past performance ratings. In addition, in USD AT&L memo dated 14 Sept 2010, reference is made to the U.S. Air Force amending their source selection methodology so that "technical, cost, and past performance factors" were more equally weighted.
I believe in a source selection environment, past performance is a significant enough consideration to warrant factor rather than sub-factor status.