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GAO Says Protester’s Strength Was Not “Strong Enough”

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The protester contended the SSA ignored one of its strengths in making the best-value determination. GAO found the SSA didn’t ignore the strength. Rather, the SSA had simply found the strength was not “strong enough” to make a difference in the best-value determination. 

Arcticom LLC, GAO B-421639.4 
  • Past Performance – The protester challenged the past performance evaluation. The protester said the agency had not accurately assessed the scope, magnitude, and complexity of the awardee’s references. GAO didn’t see it. The agency had considered each of the awardee’s references and found they demonstrated specific, relevant experience. Moreover, the agency CPARs for those performances ranged from satisfactory to exceptional. The protester’s argument amounted to disagreement with the evaluators’ conclusions. 
  • Ignored Strength – The protester said the best-value determination was flawed because the agency didn’t consider a strength the protester received under the staffing approach factor. But GAO found the agency had considered the staffing strength. The agency had simply found that the strength was not “strong enough” to raise the overall rating under the staffing factor. 

The protester is represented by Kenneth A. Martin of The Martin Law Firm, PLLC. The awardee is represented by Robert K. Palmer of the Defense Logistics Agency. GAO attorneys Uri R. Yoo and Alexander O. Levine participated in the decision. 

-- Case summary by Craig LaChance, Senior Editor 

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