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Based on its investigation into this allegation, the agency considered the nature of the recommendations IBM might make under this FSPS PWS requirement, as well as the information that would form the basis for the recommendations. In this regard, the CO noted as follows:[t]he recommendations that IBM would make regarding any abnormal balances found within the financial information are based on high-level data that pertain to multiple interfacing systems. Furthermore, A-P-T argues that the contemporaneous record reflects no meaningful assessment of the OCI or Alphaports proposed mitigation, and that the agencys explanations during this protest, in its agency report and contracting officers statement, are conclusory. As an initial matter, NASA responds that A-P-T has not shown hard facts demonstrating the existence of or potential for an OCI. In that regard, our Office has explained that a protester must identify hard facts that indicate the existence or potential existence of an OCI; mere inference or suspicion of an actual or potential conflict is not enough. NASA cites only to the labor distribution and mapping template in Alphaports FPR (rather than to any contemporaneous consideration of a possible OCI) as support for the agencys assertion that it conducted an appropriate OCI review. The SSPA required the advisor to, among other things, certify that he did not have any financial interests in any potential offerors, and to notify the chairperson of the SSEB or the CO of any changes to his financial interests that could affect his representations. There have been GAO protests based on the same facts surrounding an incumbent's [STOPs] prior personnel participating in the new solicitation and the outcome has not been favorable to the Government agencies, believe me we don't want a protest....

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