Waldo Community Action Partners v. Department of Administrative and Financial Services

2026 ME 13
CourtSupreme Judicial Court of Maine
DecidedFebruary 10, 2026
DocketBCD-25-63
StatusPublished
AuthorDOUGLAS, J.

This text of 2026 ME 13 (Waldo Community Action Partners v. Department of Administrative and Financial Services) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Waldo Community Action Partners v. Department of Administrative and Financial Services, 2026 ME 13 (Me. 2026).

Opinion

MAINE SUPREME JUDICIAL COURT Reporter of Decisions Decision: 2026 ME 13 Docket: BCD-25-63 Argued: November 14, 2025 Decided: February 10, 2026

Panel: STANFILL, C.J., and MEAD, CONNORS, LAWRENCE, and DOUGLAS, JJ.

WALDO COMMUNITY ACTION PARTNERS

v.

DEPARTMENT OF ADMINISTRATIVE AND FINANCIAL SERVICES et al.

DOUGLAS, J.

[¶1] In this appeal we consider whether a state agency violated state

procurement laws, see 5 M.R.S. § 1825-B (2025), in awarding a contract to

provide brokerage services for medical nonemergency transportation (NET) in

one of Maine’s eight identified transit regions. Pursuant to a competitive

bidding process, the Maine Department of Health and Human Services (DHHS)

awarded the contract to the highest-ranked bidder, ModivCare Solutions, LLC,

a vendor already providing the same service in several other regions of the

state, over the incumbent service provider in the area at the time, Waldo

Community Action Partners (Waldo CAP).

[¶2] Waldo CAP appealed the decision to a committee of the Department

of Administrative and Financial Services (DAFS) designated to hear appeals 2

under 5 M.R.S. § 1825-E(3) (2025). The DAFS appeal committee affirmed

DHHS’s award of the contract. Waldo CAP then filed in the Superior Court a

petition for judicial review of the appeal committee’s decision, see 5 M.R.S.

§§ 1825-F, 11001(1) (2025); M.R. Civ. P. 80C, and the court (McKeon, J.) entered

a judgment in the Business and Consumer Docket affirming the decision of the

appeal committee.

[¶3] Waldo CAP contends that both the appeal committee and the

Superior Court erred in affirming DHHS’s decision because the award of the

contract to ModivCare violated the competitive bidding statute and because the

DHHS decision was arbitrary and capricious. We disagree and affirm the

judgment upholding the award.

I. BACKGROUND

[¶4] We draw the facts from the appeal committee’s findings, which are

supported by the administrative record. See 18-554 C.M.R. ch. 120, §§ 3(4),

4(1) (effective May 24, 1995) (authorizing an evidentiary hearing before the

committee); Gray v. Dep’t of Pub. Safety, 2021 ME 19, ¶ 10, 248 A.3d 212. We

present the procedural history as reflected in the administrative and court

records. See, e.g., Pine Tree Legal Assistance, Inc. v. Dep’t of Hum. Servs., 655 A.2d

1260, 1261-62 (Me. 1995). 3

A. The Request for Proposals for NET Brokerage Services

[¶5] DHHS contracts with private entities1 to manage and coordinate

medical NET services for individuals eligible for MaineCare, which is Maine’s

Medicaid program, and the Children’s Health Insurance Program. NET services

enable eligible individuals who otherwise do not have transportation to travel

to and from covered services for nonemergency medical needs such as doctor’s

appointments and dialysis. Brokers arrange the various modes of

transportation and schedule individual trips for the users of the service.

Separate brokerage contracts are awarded for each of eight identified regions

of the State.2

[¶6] Waldo CAP has been the vendor providing NET brokerage services

for Region 5 since 2014. Several years ago, DHHS decided to put out to bid

brokerage contracts in all eight regions of the state. DHHS and DAFS jointly

When contracting for services to be provided by private entities, DHHS and all other state 1

agencies are generally required to utilize a competitive bidding process. 5 M.R.S. § 1825-B(1). DAFS, through its Bureau of General Services, oversees and assists state agencies with the purchase of goods and services. Id.; 5 M.R.S. §§ 1811(1), 1812 (2025).

2The State of Maine divides the state into eight transit regions for various administrative purposes. See Me. Dep’t of Transp., Me. Transit Regions Map, available at https://www.maine.gov/dot/sites/maine.gov.dot/files/2023- 10/TransitDistricts_2018_nolegend.pdf [https://perma.cc/Z2KM-Z7B5]. Waldo County is part of Region 5. See id. 4

developed a Request for Proposals (RFP). The RFP was posted on May 15,

2023, with a deadline for submissions of July 11, 2023.

[¶7] Part IV of the RFP set out the requirements for submitted proposals,

and at the outset stated: “This section contains instructions for Bidders to use

in preparing their proposals. The Department seeks detailed yet succinct

responses that demonstrate the Bidder’s qualifications, experience, and ability

to perform the requirements specified throughout the RFP.” The instructions

included the following admonition:

The Bidder’s proposal must follow the outline used below, including the numbering, section, and sub-section headings. Failure to use the outline specified in PART IV, or failure to respond to all questions and instructions throughout the RFP, may result in the proposal being disqualified as non-responsive or receiving a reduced score. The Department, and its evaluation team, has sole discretion to determine whether a variance from the RFP specifications will result either in disqualification or reduction in scoring of a proposal.

(Emphasis added.)

[¶8] The RFP also provided a process to address bidders’ questions: “It

is the responsibility of all Bidders and other interested parties to examine the

entire RFP and to seek clarification, in writing, if they do not understand any

information or instructions.” Questions were to be submitted to the RFP

coordinator via a designated form. The RFP coordinator did not receive any 5

questions or requests for clarification from Waldo CAP concerning the portion

of the RFP at issue here.

[¶9] Part IV also set out the required format and contents for proposals,

which were to be organized and scored in four sections:

• Section I – Preliminary Information (No points) • Section II – Organization Qualifications and Experience (25 points) • Section III – Proposed Services (50 points) • Section IV – Cost Structure Acknowledgement (25 points)

Because the cost for providing the services was fixed by state and federal

Medicaid regulations, all bidders would receive the full twenty-five-point score

for Section IV provided they included a completed, signed acknowledgement

form agreeing to be bound by state and federal rates. The highest combined

total of points awarded for Sections II and III, therefore, would determine the

successful bidder in each region.

[¶10] Section II required bidders to submit additional information in an

appendix, instructing bidders as follows:

Bidders must complete Appendix D (Qualifications and Experience Form) describing their qualifications and skills to provide the requested services in the RFP. Bidders must include three examples of projects which demonstrate their experience and expertise in performing these services as well as highlighting the Bidder’s stated qualifications and skills. 6

(Emphasis added.) Appendix D prescribed a specific format for providing the

information requested, namely four discrete blocks or boxes.

[¶11] In the first box, bidders were instructed to “[p]resent a brief

statement of qualifications, including any applicable licensure and/or

certification.” There, bidders were required to “[d]escribe the history of [their]

organization” with reference to “skills pertinent to the specific work required

by the RFP and any special or unique characteristics of the organization which

would make it especially qualified to perform the required work activities.” If

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Bluebook (online)
2026 ME 13, Counsel Stack Legal Research, https://law.counselstack.com/opinion/waldo-community-action-partners-v-department-of-administrative-and-me-2026.