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GAO Says Incumbent Price Is All You Need to Assess Price Reasonableness

Andrii Yalanskyi | Shutterstock

The protester argued the agency conducted a flawed price evaluation because it only compared the proposed prices to the incumbent's price. GAO found this to be a fair method of conducting price evaluations based on FAR 15.

MCI Diagnostic Center, LLC, GAO B-422777; B-422777.2
  • Solicitation - The agency sought medical laboratory and testing analysis services to support its facilities. After receiving proposals, the agency evaluated prices and found the protester's proposed price 30.49 percent above the agency's independent government cost estimate (IGCE). As a result, the agency excluded the protester's proposal from the competition.
  • Protest - The protester argued the price evaluation was deficient because it was based on a flawed IGCE. Specifically, the protester claimed, "The incumbent contract price alone without consideration of any differences in the scope of that contract" was an inadequate price comparison. GAO was unpersuaded. FAR 15.404-1(b)(2)(i) identified this method as a fair and reasonable evaluation method. 

The protester was represented by Amy C. Hoang, Erica L. Bakies, and Sarah E. Barney of Seyfarth Shaw LLP. The agency was represented by Jared Levin of the Department of Veterans Affairs. Heather Weiner and Jennifer D. Westfall-McGrail of GAO participated in the preparation of the decision.

-- Case summary by Joshua Lim, Assistant Editor

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