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How Did the Agency Flub this Best-Value Tradeoff?

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The protester challenged the agency’s best-value tradeoff. GAO sustained, finding the tradeoff was based on little more than a mechanical comparison of numerical scores without any comparison between the awardee’s and the protester’s proposals. In fact, the award decision didn't even mention the protester’s proposal. GAO recommended a new best-value determination.

R&K Enterprise Solutions, Inc., GAO B-419919.6

Background

The Air Force issued a solicitation to small business holders of GSA’s One Acquisition Solution for Integrated Services IDIQ contract. The solicitation sought a variety of training, operations, and administrative services. Proposals would be assigned a numerical score under the technical factor, called the weighted total evaluation score.

Nine offerors submitted proposals, but only three, including R&K Enterprise Solutions and Cyber Engineering and Technical Alliance (CTEA), were eligible for award. R&K had the cheaper proposal, but CTEA had the higher weighted evaluation score. The Air Force awarded the contract to CTEA, finding the company’s technical superiority warranted the price premium. R&K protested.

Analysis

Technical Evaluation

R&K challenged the technical evaluation, arguing the agency assigned too many weaknesses and not enough strengths to its proposal. GAO rejected R&K’s arguments. GAO determined the weaknesses assessed to R&K’s proposal were warranted. Parts of R&K’s technical proposals were superficial and failed to demonstrate understanding of operational problems. R&K’s proposal also failed to address certain solicitation requirements. As to the strengths the Air Force allegedly failed to assign, GAO found that R&K simply disagreed with the evaluation conclusions.

Best-Value Tradeoff

R&K also objected to the best value tradeoff arguing that it only consisted of a mechanical comparison between proposals and that the agency had failed to compare CETA’s and R&K’s proposals. GAO found the best value arguments more compelling.

A source selection based on a mechanical application of point scores without any qualitative assessment of proposals is unreasonable. Here, the award decision was based entirely on a comparison of numerical point scores. There was no comparison between CETA’s proposal and R&K’s. In fact, there was not mention of R&K’s proposal at all. GAO recommended the agency conduct a new best-value tradeoff.

R&K is represented by Kevin P. Connelly, Kelly R. Buroker, and Tamara Droubi of Vedder Price P.C. The intervenor, CETA, is represented by William T. Welch, J. Patrick McMahon, and Lewis Rhodes of McMahon Welch and Learned, PLLC. The agency is represented by Colonel Frank Yoon and Isabelle P. Cutting of the Air Force. GAO attorneys David A. Edelstein and Alexander O. Levine participated in the preparation of the decision.

–Case summary by Craig LaChance, Senior Editor

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