64471

Parrish Business Services, LLC

October 13, 2026Judge McLish
OtherCDA JurisdictionContract Changes / Constructive ChangesEquitable Adjustment (REA)Small BusinessCommercial Item

NASA awarded Parrish Business Services, LLC a firm-fixed-price contract for virtual anti-harassment training, later removing live training requirements and denying Parrish's request for additional compensation. The ASBCA denied the government's motions to dismiss, holding that Parrish submitted a valid CDA claim, timely appealed after detrimental reliance on an erroneous appeal-rights notice, and adequately stated a claim at the pleading stage.

Material Facts

  • NASA awarded Parrish a firm-fixed-price commercial contract to deliver virtual anti-harassment trainings to NASA personnel.
  • The contract was a small-business set-aside with a stated performance period from September 26, 2024, through August 31, 2025.
  • NASA removed a DEIA Plan deliverable and later removed all live training classes from the contract.
  • Parrish asserted that it incurred costs preparing for and remaining ready to provide the live training classes before NASA removed those requirements.
  • Parrish executed the descoping modification under protest and reserved its rights.
  • Parrish repeatedly requested a contracting officer's final decision under the CDA.
  • The contracting officer's final decision incorrectly stated that Parrish could appeal to the CBCA.
  • Parrish filed first at the CBCA and filed at the ASBCA after the CBCA advised that the ASBCA was the proper forum.

Parties

Appellant
Parrish Business Services, LLC
Respondent Agency
National Aeronautics and Space Administration (NASA)
Contracting Agency
National Aeronautics and Space Administration (NASA)
Contract Number
80NSSC24PC460
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