Protest alleging that agency failed to conduct a proper price realism analysis is denied. GAO found that the agency effectively reviewed price realism by evaluating professional compensation. The solicitation only had a single evaluation factor, namely, price. The solicitation only sought instructors so the only price to be evaluated was the compensation of the instructors. In evaluating that compensation, the agency essentially evaluated the vendors’ understanding of the requirements and ability to perform, the very things that would have been considered in a price realism analysis.
The Army issued an RFQ seeking personnel to instruct a training team course at Ft. Sill, Oklahoma. The RFQ include one evaluation factor: price. The RFQ stated that the Army would evaluate prices for reasonableness and that prices evaluated as unrealistically low may be eliminated from further consideration. The RFQ also included FAR 52.222-46, which stated the Army would evaluate the professional compensation of the instructor proposed.
The Army received four quotations; the agency selected Cornerstone Signals & Cyber Technologies for award. An unsuccessful vendor, People, Technology and Processes, LLP (PTP), protested, arguing that the Army failed to conduct a price realism analysis required by the RFQ.
GAO agreed that the RFQ required the Army to conduct a price realism analysis. The RFQ stated that quotations with unrealistically low prices could be eliminated. This language mandated an assessment of price realism.
Nevertheless, GAO determined that the Army had effectively evaluated price realism by evaluating professional compensation under the FAR 52.222-46. The RFQ only had one price factor, and the only price at issue was the compensation of the instructors. Thus, the evaluation under FAR 52.222-46 necessarily assessed vendors’ understanding of the requirement, whether they could perform the requirements of the contract, and whether vendors would be able to recruit qualified personnel. This was essentially the same thing that would have been evaluated under a price realism evaluation conducted in accordance with FAR 15.406-1(d)(3). PTP had not explained what more a price realism analysis would have required that was not already reviewed under the professional compensation evaluation.
PTP is represented by Victor L. Buonamia. The agency is represented by Major Mark T. Robinson and Major Aaron K. McCartney of the Army. GAO attorneys Raymond Richards, Edward Goldstein, John Sorrenti participated in the preparation of the decision.
