The protester alleged the agency botched the cost realism evaluation because it did not compare costs to the government estimate or the solicitation's price range. GAO denied the protest, finding the agency was not bound by price estimates in the solicitation and that the agency properly relied on other cost comparisons.
BTAS, Inc., GAO, B-422624.2; B-422624.6
- Background - GSA issued a task order request for proposals under its OASIS small business contract for advisory and assistance services, including acquisition, financial, and administrative capabilities for space-related research and development programs. After initially awarding to the awardee in May 2024, GSA took corrective action following another protest and reevaluated proposals. GSA again selected the awardee based on its "good" technical rating and lower evaluated price of $221.8 million compared to BTAS's $259.4 million. The protester argued GSA improperly ignored the solicitation's estimated price range of $275-336 million and failed to credit its technical proposal with additional strengths.
- Cost Realism - The protester argued GSA erred in using the solicitation's estimated total evaluated price range ($275-336 million) or the government estimate ($327.7 million) in its cost realism analysis. GAO rejected the argument. The solicitation stated the range was provided to help offerors "gauge the magnitude of the requirement" but did not require proposals to fall within that range. Also, GSA reasonably found the government estimate too high because it didn't account for competitive pricing discounts. Instead, GSA properly compared proposed rates to each other and to Bureau of Labor Statistics wage data.
- Technical Reevaluation - BTAS argued it deserved an "exceptional" rating rather than "good" because GSA initially assigned more strengths to its proposal before corrective action. GAO noted agencies may reach different conclusions during reevaluation and need not explain differences absent evidence of impropriety. During reevaluation, GSA assessed fewer strengths but also removed several weaknesses from BTAS's proposal. The agency explained during debriefing that BTAS's strengths did not merit an exceptional rating. BTAS failed to identify specific proposal language demonstrating how it exceeded requirements to warrant additional strengths.
The protester is represented by William Pannier of Pannier Law, PC. The intervenor, Credence Management Solutions, LLC, is represented by J. Scott Hommer, III, Rebecca E. Pearson, Christopher G. Griesedieck, Jr., and David L.W. Smith of Venable, LLP. The government is represented by William R. Black of the General Services Administration. GAO attorneys Heather Weiner and Jennifer D. Westfall-McGrail participated in the decision.