Blackstone Consulting, Inc.

Armed Services Board of Contract Appeals·Decided July 30, 2026·No. 64558·Published

Opinion

ARMED SERVICES BOARD OF CONTRACT APPEALS

Appeal of - )

)

Blackstone Consulting, Inc. ) ASBCA No. 64558 )

Under Contract No. HQ0847-24-D-0001 )

APPEARANCE FOR THE APPELLANT: Daniel F. Edwards, Esq.

The Law Office of Daniel F. Edwards, LLC Dublin, OH

APPEARANCES FOR THE GOVERNMENT: Brandon R. Cogswell, Esq.

Chief Counsel – Acquisition Law Stephan Piel, Esq. John B. Alumbaugh, Esq. Assistant General Counsel DoW Washington Headquarters Services Washington, DC

OPINION BY ADMINISTRATIVE JUDGE EYESTER ON THE GOVERNMENT’S MOTION TO DISMISS

Appellant Blackstone Consulting, Inc. (BCI) appeals a contracting officer’s final decision denying its claim for German labor law costs resulting from a decision by the Washington Headquarters Services (WHS) to stop ordering services pursuant to BCI’s indefinite delivery, indefinite quantity contract. BCI contends WHS delayed disclosure of this information, thus causing an increase in the mandatory labor costs owed under German law. BCI presented three theories for recovery: breach of good faith and fair dealing, superior knowledge, and “Alternative Relief Based on Government Representations and Contract Administration.”

BCI elected to utilize the Board’s accelerated procedures pursuant to Rule 12.3.

Subsequent to the election, WHS filed a motion to dismiss the entire appeal for failure to state a claim. For the reasons discussed below, we dismiss the appeal.

STATEMENT OF FACTS (SOF) FOR PURPOSES OF THE MOTION

1. On June 27, 2024, the Washington Headquarters Service (WHS) awarded Blackstone Consulting, Inc. (BCI) an indefinite delivery, indefinite quantity (IDIQ) contract for meal services at the George C. Marshall Center Dining Facility Operations and Support Services Center located in Germany (R4, tab 1 at 1-3, 15, tab 2). The

IDIQ contract included six contract line items (CLINs) with estimated quantities, as follows: CLINs 01-05 were fixed unit-priced per meal and CLIN 06 was fixed unit- priced per month for operational support (R4, tab 1 at 3, 15).

2. CLIN 06 for operational support required BCI furnish all labor, personnel, materials, and other items necessary to support the center in accordance with the performance work statement (PWS), attachments, and local German labor laws (R4, tab 1 at 7). Specifically, the IDIQ contract stated that for operational support services, “[c]ompliance with German law is a material contract requirement” (id. at 50).

3. The IDIQ contract explicitly stated it was for non-personal services, with an individual acting as an independent contractor and thus the contractor was “solely” responsible for reporting and payment obligations under the Host nation tax and labor laws (R4, tab 1 at 3). Again, the IDIQ contract stated that BCI “shall comply with German law” (id. at 33).

4. The IDIQ contract incorporated by reference Federal Acquisition Regulation (FAR) 52.212-4, CONTRACT TERMS AND CONDITIONS—COMMERCIAL PRODUCTS AND COMMERCIAL SERVICES (NOV 2023) (R4, tab 1 at 10). According to this clause, the schedule of supplies/services takes precedence over everything else in the IDIQ contract in the event there is any inconsistency. FAR 52.212-4(s). The IDIQ contract’s schedule of supplies/services set forth an ordering period of July 1, 2024 through May 31, 2029, with a six-month option to extend (R4, tab 1 at 3). In other words, the schedule, which is controlling, provided for a nearly five-year ordering period, with a single six-month option to extend. Likewise, FAR 52.216-18, ORDERING (AUG 2020), incorporated in full in the contract, stated that “orders may be issued from June 1, 2024 through May 31, 2029” (id. at 14). Further, the IDIQ contract’s delivery requirements show the period of performance as July 1, 2024 through May 31, 2029 (id. at 8-9). FAR 52.216-22, INDEFINITE QUANTITY (OCT 1995), incorporated in full, stated the contract was an indefinite quantity contract for the listed supplies/services “and effective for the period stated, in the Schedule” (id. at 15). However, in the PWS of the IDIQ contract, there was a contradictory provision that stated the period of performance was one base period of 12 months, four 12-month option periods, and one six-month extension (id. at 32).

5. With respect to options, the IDIQ contract set forth in full FAR 52.217-8, OPTION TO EXTEND SERVICES (NOV 1999), which explained WHS may require BCI continue performance “of any services within the limits and at the rates specified in the contract” which would be adjusted only for prevailing labor rates provided by the Secretary of Labor. The contracting officer was required to notify BCI it was exercising the option within 30 days prior to the IDIQ contract expiration. (R4, tab 1 at 15) The IDIQ contract did not include FAR 52.217-9, OPTION TO EXTEND THE TERM OF THE CONTRACT (see id.).

6. The IDIQ contract further stated: “It is understood and agreed that the Government has no obligation to issue any Task Orders except the minimum order” (R4, tab 1 at 3). The IDIQ contract minimum was $3500 (id. at 7). The FAR indefinite quantity clause, 52.216-22(b), stated that delivery or performance “shall be made only as authorized by orders issued in accordance with the Ordering clause” and that the contractor (BCI) shall furnish the supplies/services “when and if ordered” (id. at 15). Likewise, per the IDIQ contract’s ordering instructions, services were to be provided “solely at such times as ordered by the issuance of Task Orders by the Contracting Officer.” The IDIQ contract further stated: “It is understood and agreed that the Government has no obligation to issue any Task Orders except the minimum order.” (R4, tab 1 at 3)

7. The FAR 52.216-18, ordering clause also explained that all orders would be subject to the IDIQ contract’s terms and conditions. If there was any conflict between the terms and conditions, the IDIQ contract controlled. (R4, tab 1 at 14)

8. On June 11, 2025, WHS notified BCI that pursuant to FAR 52.217-9, the option to extend the term of the IDIQ contract, it was exercising option year 1, and this notification “DOES NOT commit” WHS to exercise the option or obligate funds against the IDIQ contract, but was for planning purposes (R4, tab 8 at 1). As noted, the IDIQ contract did not include FAR 52.217-9, OPTION TO EXTEND THE TERM OF THE CONTRACT (see SOF ¶ 5). WHS requested the 12-month period of performance change such that it would become two, six-month periods (July 1, 2025 through December 31, 2025 and January 1, 2026 through June 30, 2026) (R4, tab 8 at 1). BCI agreed to the change (R4, tab 9 at 2). In response, the contracting officer explained that the Marshall Center was expecting a lower participant turnout and would request a quotation for a task order once the government completed its independent estimate (id. at 1).

9. On June 30, 2025, the contract specialist issued a task order for a six-month period of performance and stated “[w]hen the subsequent 6-month option period will be exercised, it will be a separate task order” (R4, tab 10 at 1). The issued task order was fixed-price, and its period of performance was from July 1, 2025 through December 31, 2025 (R4, tab 6 at 3-7, 11). CLIN 06 of the task order, like CLIN 06 for the IDIQ contract, was for operational support and included all labor, personnel, supplies, materials, and other necessary items to provide support to the facility in accordance with the performance work statement (id. at 6-7). CLIN 06 pricing also included all other requirements, including compliance with local German labor laws (id.).

10. On July 31, 2025, WHS met to discuss the IDIQ contract (R4, tab 11). On September 18, 2025, WHS notified BCI that it would not be exercising the second,

six-month option with the January 1, 2026 through June 30, 2026 period of performance, nor the remaining option years (R4, tab 12).

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