Courts, Boards, & GAO

Trending Now
Why Didn’t this Protester’s Status as a Small Business Satisfy the Solicitation’s Small Business Participation Requirement? • Contractor Tried to Salvage a Dismissed Claim By Changing Its Legal Theory. The COFC Wasn’t Feeling It. • Clarified Standard for Challenging CICA Stay Overrides • Fixed-Price Contracts EO: What It Means for Government Contractors • National Geospatial-Intelligence Agency to Open Programs to More Vendors

Solicitation Required Experience of Similar Size, Scope and Complexity. How Similar Must that Experience Be?

The solicitation sought IT services for the National Institutes of Health. The protester argued the awardee didn’t satisfy the solicitation’s experience requirement. The protester contended the awardee lacked IT experience in a health-specific environment. But GAO found nothing in the solicitation limited experience to health-specific environments. Offerors only needed to show they had experience of similar size, scope, and complexity. The awardee reasonably satisfied this requirement with work that was not health-specific.

Computer World Services Corporation, GAO B-420777.2. B-420777.3

Background

The Department of Health and Human Services (HHS) issued a solicitation to small business holders of the NIH’s Chief Officer Solutions and Partners 3 IDIQ contract. The solicitation sought service desk staffing for NIH’s Center for Information Technology.

Seven offerors, including Computer World Services Corporation (CWS) and Ideation Solutions JV, submitted proposals. HHS awarded the contract to CWS. Ideation protested. In response to the protest, HHS took corrective action.

HHS reevaluated proposals and held discussions. HHS determined CWS’s and Ideation’s revised proposals were technically equal. Ideation, however, had the lower price, so it got the award. CWS protested.

Analysis

Discussions

CWS alleged HHS didn’t conduct meaningful discussions. CWS complained HHS didn’t raise a concern it had with CWS’s lack of innovation. But GAO found that HHS wasn’t required to raise this concern. An agency is not required to advise of a weakness that’s not significant, even if that weakness is determinative. Here, the contracting officer had made a comment about CWS’s lack of innovation, but HHS never found that issue to be a significant weakness.

Key Personnel

In response to questions from offerors, HHS had stated that offerors should not replace all incumbent employees. In light of this comment, CWS argued the agency should have penalized Ideation for not retaining incumbent staff.

GAO noted that while HHS had expressed a preference for incumbent employees, the solicitation had not required offerors to retain incumbent staff. HHS had raised the incumbent issue with Ideation during discussions. Ideation responded by describing its efforts to recruit incumbent personnel using the same staffing approach on another contract. HHS reasonably found Ideation’s staffing approach was not a weakness.

Experience

CWS contended Ideation lacked required experience. The solicitation required offerors to identify experience references that were similar in size, scope, and complexity. CWS argued Ideation had not satisfied this requirement because it had not demonstrated experience performing IT services in a health-specific environment.

GAO found nothing in the solicitation limited the type of experience HHS would consider to health-specific environments. Rather, offerors simply had demonstrate experience on contracts that were similar in size and scope. Ideation had satisfied this requirement by performing IT-related services for the Department of Agriculture and the Patent and Trademark Office.

CWS is represented by Matthew T. Schoonover, Matthew P. Moriarty, John M. Mattox II, Ian P. Patterson, and Timothy J. Laughlin of Schoonover & Moriarty LLC. The intervenor, Ideation, is represented by Kara L. Daniels and Cate Baskin of Arnold & Porter Kaye Scholer, LLP. The agency is represented by Ethan Chae and Jon Gottschalk of the Department of Health and Human Services. GAO attorneys Heather Weiner and Jennifer D. Westfall-McGrail participated in the decision.

--Case summary by Craig LaChance, Senior Editor

GAO - Computer World Services Corporation

Get daily insights on bid protests, CDA claims, and contract litigation that shape the GovCon landscape with our Protests & Claims newsletter, delivering up-to-the-minute intelligence Monday–Saturday — Subscribe here.