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B-188454 1 (1979-01-15)

handle is hein.gao/gaobadguw0001 and id is 1 raw text is: THE COMPTROLLER GENERAL DECISION . OF THE UNITED STATES WASHINGTON. D.C. 20548 FILE: B-188454 MATTER OF: DATE: January 15, 1979 Molitor & Grayson DIGEST: Payment for management and technical assistance services providedsmall business concerns under expired SBA contract may be made on quantum meruit basis since Government received benefit and unauthorized action has been implicitly ratified. The Small Business Administration (SBA) has L 6 requested our decision on whether Molitor & Grayson (M&G), a Seattle, Washington, Certified Public Accounting firm, is entitled to payment of $5,456.85 for services rendered after its contract with SBA had expired. On February 24, 1977, M&G was awarded a 1-year contract by SBA to provide management and technical assistance services to eligible small business con- cerns. The services required under.this contract were to be provided whenever the SBA Program Manager issued a task order. However, due to administrative error, the SBA Program Manager continued to issue task orders after the expiration of M&G's contract. Having been informed orally that the contract had been extended, M&G did not question these additional task orders and continued to perform. M&G now claims $5,456.85 as the reasonable value for the services it provided beyond the term of the contract. Although the United States cannot be bound beyond the actual authority conferred upon its agents by statute or regulation, see United States v. Crance, 341 F.2d 161, 166 (1965), the courts and our Office have recognized that in appropriate circumstances pay- ment may be made for services rendered on a quantum LF~~ 4 Se'ce$ S 1~e Conqvn.ci Epnti'Jj w

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