The protester alleged the agency failed to qualitatively assess proposals under a solicitation subfactor. The protester complained that the agency had not assessed any strengths or weaknesses to any offeror under the subfactor and assigned each offeror the same rating. But GAO found that the absence of strengths and weaknesses didn’t necessarily mean the agency failed to assess the quality of proposals. Rather, the record showed the agency had assessed proposals and simply concluded they were all fairly vanilla; there was no basis to discriminate between them.
Alion Science & Technology Corporation, GAO B-420778, B-420778.2
Background
The Air Force issued a solicitation to holders of DoD’s Information Analysis Center IDIQ contract. The solicitation contemplated award of a task order for research and development services. The Air Force received proposals from Alion Science & Technology Corporation and ManTech-TSG-2 Joint Venture. The Air Force awarded the contract to ManTech. Alion had a few evaluated advantages, but the Air Force determined those advantages were not worth Alion’s $23 million price premium. Alion protested.
Analysis
Additional Strengths
Alion contended it should have received additional strengths for proposing highly-skilled incumbent personnel. GAO wasn’t convinced. Nothing in the solicitation required the Air Force to evaluate whether offerors proposed incumbent personnel. The Air Force reasonably concluded that Alion’s proposal didn’t merit additional strengths.
Qualitative Evaluation
Alion asserted the Air Force failed to qualitatively evaluate proposals under a labor basis of estimate subfactor. Alion complained that the evaluation under this subfactor was “hollow”—it reflected no strengths or weaknesses and assigned all proposals the same technical rating.
GAO, however, found the record clearly showed that the Air Force reviewed labor hours and separately considered each offeror’s labor mix under the subfacor. While the agency had not assessed strengths and weaknesses and assigned the same rating to each proposal, this was because it reasonably found no basis to discriminate between proposals.
Lack of Detail
Alion argued the Air Force erred in assessing its proposal a weakness for lacking detail regarding the company’s methods for transferring data from the development environment to the production environment. But GAO found this weakness was justified. Alion had not provided details or explained its methods for transferring data.
Alion is represented by Michael F. Mason, Stacy Hadeka, Christine Reynolds, Adilene Rosales, and Lauren Olmstead of Hogan Lovells US LLP. The intervenor, ManTech TSG-2, is represented by Kevin P. Mullen, W. Jay DeVecchio, James A. Tucker, Lyle E. Hedgecock, and Victoria Dalcourt Angle of Morrison & Foerster LLP. The agency is represented by Colonel Frank Yoon, Michael J. Farr, Siobhan K. Donahue, and Kenneth J. Leroy of the Air Force. GAO attorneys Christopher Alwood and Alexander O. Levine participated in the preparation of the decision.
–Case summary by Craig Lachance, Senior Editor
