15/09/2025
Bid Splitting: Comfort Cuts Paid Through Multiple Purchase Orders Without Competitive Bid Process
By Troy Torres, Kandit News
Department of Chamorro Affairs disclosures of procurement and financial documents involving Comfort Cuts show a practice commonly known as bid splitting in order to pay the business without going through the competitive bid process during the pandemic.
Records involving Comfort Cuts' janitorial and grass cutting services at the Chamorro Village show DCA was paying Comfort Cuts through a series of purchase orders during the public health emergency. The records begin in March 2020 - the same month the pandemic and the public health emergency began.
According to Guam law, agencies must put out to competitive bid process any procurement for services and products that would exceed costs of $24,999.99 in a given fiscal year.
According to invoices and purchase orders, DCA authorized and purportedly paid Comfort Cuts $33,182.50 for the final seven months of Fiscal Year 2020.
For Fiscal Year 2021: $31,500.
And for Fiscal Year 2022: $63,500.
Bid splitting is illegal.
According to the Emergency Health Powers Act, the governor during the public health emergency was able to curtail procurement regulations, but only for the procurement of emergency supplies and services directly related to the public's health. The Chamorro Village was either closed or minimally operational during this period, and served no public health purpose.
Comfort Cuts is owned and operated by Frankie Rosalin and his girlfriend Charissa Tenorio, who is Lieutenant Governor Joshua Tenorio's sister. The couple, along with Mr. Tenorio's boyfriend Matthew Topasna and four others face criminal trial starting December from a June 25, 2025 indictment by the grand jury. The case stems from a multiyear FBI investigation and federal allegations that the seven defendants conspired to steal at least $1.9 million from the federal government and from the poor through the Pandemic Unemployment Assistance program. That case is unrelated to this review of contracts Comfort Cuts has had with government agencies since Mr. Tenorio came to office.
Kandit's FOIA Requests
In late January, Kandit sent a Freedom of Information Act request to DCA president Melvin Won Pat Borja for copies of all of the agency's contracts and purchase orders issued since 2019. In early February, Mr. Won Pat Borja disclosed the documents. The disclosure shows several purchase orders from Fiscal Years 2020 through 2022 that were broken up, each under the $25,000 threshold that would have triggered a competitive bid process.
There were no contracts or records indicating any competitive bid process took place that would have authorized DCA's expenditure of more than $24,999.99 on Comfort Cuts services at the Chamorro Village for any of those fiscal years. Neither did any of the purchase orders cite any General Services Agency procurement number corresponding to a competitive bid process or otherwise a contract for services.
Kandit in August requested the invoices Comfort Cuts sent to DCA that DCA and the government paid. Mr. Won Pat Borja provided the documents last week.
Fiscal Year 2020: Purchase Order and Invoice Records Do Not Match
DCA's February disclosure of the purchase orders to Comfort Cuts shows the agency began to authorize payments through three separate purchase orders that begin in June 2020. The first is for $12,600 for June and July. The second for $6,300 for August. And the last purchase order for $4,300 for September. The amount totals $23,200, or under the statutory bid trigger.
However, invoices from Comfort Cuts that were part of the August DCA disclosure show the agency paying billings by Comfort Cuts starting in March that year. According to the disclosures, Comfort Cuts was performing work and being paid for that work at the Chamorro Village for at least three months without any purchase order or contract. The total for the seven months of billings far exceeded the $24,999.99 annual cap, or $33,182.50 in total charges for the seven months involved.
Fiscal Year 2021: Won Pat Borja Bid Split $34,900 Among 9 Purchase Orders
In Fiscal Year 2021, Mr. Won Pat Borja signed off on nine purchase orders, each ranging from $2,150 to $8,750 that totaled $34,900 to Comfort Cuts, or nearly $10,000 above the statutory trigger for a competitive bid process.
Invoices from Comfort Cuts for that fiscal year show that the business charged $31,500 that fiscal year.
The following fiscal year, however, Comfort Cuts charged and purportedly was paid more than double its FY 2021 billings.
Fiscal Year 2022: $63,500 in Billings, Only $51,700 In Purchase Orders, No Competitive Bid
According to the purchase orders and records for Comfort Cuts for its Chamorro Village services in Fiscal Year 2022, DCA issued 9 purchase orders authorizing payments of up to $51,700, but Comfort Cuts charged $63,500 that fiscal year.
Both amounts are grossly violative of the government's $24,999.99 competitive bid threshold.
The purchase orders each range from authorizations of $2,000 to up to $12,800, which make each procurement appear to be well below the $24,999.99 limit before DCA was supposed to issue an invitation for bid in a competitive procurement process.
