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Protester Challenged a Deficiency Assessed to Its Proposal. Why Did GAO Think the Deficiency Was Warranted?

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The protester challenged the agency's assignment of a deficiency under the smart building support services factor. GAO found the deficiency was reasonably assigned because the protester's quotation only emphasized generalized project management services, not knowledge or experience with smart building technology.

Booker DiMaio, LLC, B-423224
  • Protest - The protester challenged the agency's evaluation of its quotation for multiple blanket purchase agreements (BPAs) to provide project management support services. Specifically, it argued that the assignment of a deficiency under the smart building support services was unreasonable because the agency applied an unstated evaluation criteria.
  • Agency Response - The agency responded the evaluation was reasonable because the protester's quotation did not address the smart building support task area. Allegedly, it simply emphasized generalized project management services and failed to show how the protester intended to meet the requirement.
  • Decision - GAO sided with the agency. The protester's quotation failed to demonstrate knowledge of smart building technology. The evaluators rightly were concerned that the protester's quotation lacked experience and expertise because it was "written with very basic project management references." Thus, the protester was denied.

The protester was represented by Patrick Kernan, Esq., Asmar, Schor & McKenna, PLLC. The agency was represented by Shirin Ahlhauser of GSA. Sarah T. Zaffina 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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