Primary Health Care, LLC v. United States

CourtUnited States Court of Federal Claims
DecidedMay 28, 2026
Docket25-1795
StatusPublished

This text of Primary Health Care, LLC v. United States (Primary Health Care, LLC v. United States) is published on Counsel Stack Legal Research, covering United States Court of Federal Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Primary Health Care, LLC v. United States, (uscfc 2026).

Opinion

In the United States Court of Federal Claims No. 25-1795C (Filed Under Seal: May 12, 2026) (Reissued: May 28, 2026) FOR PUBLICATION *************************************** PRIMARY HEALTH CARE, LLC, * D/B/A ANGLIN DISTINCTIVE * HEALTH CARE JV, LLC, * * Plaintiff, * * v. * * THE UNITED STATES, * * Defendant. * * *************************************** Meghan F. Leemon, PilieroMazza PLLC, Washington, D.C., for Plaintiff. Also on the briefs was Eric A. Valle, PilieroMazza PLLC, Washington, D.C. Ioana C. Meyer, Trial Attorney, Commercial Litigation Branch, Civil Division, United States Department of Justice, Washington, D.C., for Defendant. Also on the briefs were Brett A. Shumate, Assistant Attorney General; Patricia M. McCarthy, Director, and Steven Michael Mager, Assistant Director, Commercial Litigation Branch, Civil Division, United States Department of Justice. OPINION AND ORDER In this post-award bid protest, Primary Health Care, LLC challenges a Small Business Administration (“SBA”) finding that it is “other than small.” Compl. ¶ 4 (ECF 1). The parties’ cross-motions for judgment on the administrative record are fully briefed, and I have heard oral argument.1 Defendant’s motion to file its reply out of time (ECF 27) is GRANTED. See Tr. at 6.

 Pursuant to the protective order in this case, the Court initially filed this opinion under seal on

May 12, 2026, for the parties to propose redactions of confidential or proprietary information. The parties were directed to propose redactions by May 26, 2026. The parties notified the Court on May 26 that there were no proposed redactions. The Court hereby releases publicly the opinion and order of May 12 in full. 1 Pl.’s MJAR (ECF 23); Def.’s Mot. to Dismiss, Cross-MJAR & Resp. (ECF 25) (“Def.’s MJAR”); Pl.’s

Resp. & Reply (ECF 26); Def.’s Reply (ECF 28); see also Oral Arg. Tr. (“Tr.”) (ECF 36). Because the SBA’s decision was not arbitrary or capricious, Plaintiff’s motion for judgment on the administrative record is DENIED. Defendant’s cross-motion for judgment on the administrative record is GRANTED.

BACKGROUND I. Regulatory Background The SBA administers statutes and regulations intended to ensure that small businesses can compete for and obtain federal procurement contracts. Two aspects of those regulations are relevant here: size determinations and the mentor-protégé program. A. Size Determinations The federal government sets goals for awarding procurement contracts to small businesses. See 15 U.S.C. § 644(a)(1)(C), (g). To meet those goals, agencies regularly “set aside” procurements that only small businesses may compete for. Whether an offeror counts as “small” depends on whether it meets the SBA’s size standard for that procurement. The SBA’s size standards derive, in turn, from industry-specific standards listed in the North American Industry Classification System (“NAICS”). 13 C.F.R. §§ 121.101(a), 121.201, 121.402(a)–(b) (2022).2 The general rule for joint ventures is that they do not qualify as small unless each member of the venture is small. 13 C.F.R. § 121.103(h)(1)(i). There is one relevant exception to that rule, discussed below. When a business bids on a small-business set-aside contract, it must self- certify that it meets the solicitation’s size standard. 13 C.F.R. §§ 121.404(a), 121.405(a). Offerors submit a self-certification “as part of [their] initial offer or response which includes price.” 13 C.F.R. § 121.404(a). The self-certification is generally accepted at face value, absent contrary evidence or an objection from other offerors. See 13 C.F.R. § 121.405(b). The date of self-certification is the default date for determining the offeror’s size. 13 C.F.R. § 121.404(a). That “snapshot-in-time” rule means that if a business qualifies as small under the relevant size standard on the date when it submits an offer, it still qualifies as small even if it outgrows the size standard by the time the contract is ultimately awarded. 13 C.F.R. § 121.404(g); see also Small Business Size Regulations, 76 Fed. Reg. 8222, 8249 (Feb. 11, 2011).

2 All Code of Federal Regulations citations are to the version in place at the date of the Solicitation,

November 15, 2022, unless otherwise specified. See Cont. Servs., Inc. v. United States, 104 Fed. Cl. 261, 264 n.10 (2012); Int’l Mgmt. Servs., Inc. v. United States, 80 Fed. Cl. 1, 9 n.14 (2007).

-2- The SBA authorizes offerors participating in a set-aside solicitation to initiate “size protests” challenging another offeror’s eligibility. 13 C.F.R. §§ 121.405(c), 121.1001(a)(1)(i), (2)(i). The SBA Government Contracting Area Office reviews the challenged offeror and issues a size determination. 13 C.F.R. §§ 121.1008, 121.1009. That size determination may be appealed to the SBA Office of Hearings and Appeals. 13 C.F.R. § 121.1101. B. Mentor-Protégé Program The small business mentor-protégé program incentivizes experienced government contracting firms to mentor developing small-business protégés. 13 C.F.R. § 125.9. Most importantly for this case — in an exception to the usual size rule mentioned above — the mentor and protégé may form joint ventures to compete for contracts as small businesses. A mentor-protégé joint venture qualifies as small for a procurement so long as the protégé would qualify as small, and provided other conditions are met. 13 C.F.R. §§ 121.103(h)(1)(ii), 125.9(d)(1). To participate in the program, the mentor and protégé must enter a written mentor-protégé agreement, which must then be approved by the SBA. 13 C.F.R. § 125.9(e). The contents of mentor-protégé agreements are governed by regulation. Among other requirements, a mentor-protégé agreement “must provide that either the protégé or the mentor may terminate the agreement with 30 days advance notice to the other party to the mentor-protégé relationship and to SBA.” 13 C.F.R. § 125.9(e)(4). The SBA conducts annual evaluations of the mentor-protégé relationship to ensure that the protégé is receiving sufficient developmental assistance from its mentor. 13 C.F.R. § 125.9(g). With an approved agreement in hand, the mentor and protégé may joint venture as a small business. The joint venture must be governed by a joint venture agreement — in addition to the mentor-protégé agreement — which must also contain certain mandatory terms. See 13 C.F.R.

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