Parrish Business Services, LLC
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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