The protester objected to its technical rating, arguing the agency mechanically counted strengths and weaknesses without weighing those strengths and weaknesses. GAO sustained. The agency unreasonably determined the protester’s strengths and weaknesses offset one another but didn’t explain how or why they offset.
Cadre5, LLC, GAO B-42216
- Evaluation – The agency assessed the protester three strengths and three weaknesses under the solicitation’s technical factor. The agency concluded these strengths and weaknesses offset, resulting in an acceptable technical rating. The agency determined a quotation with a mere acceptable rating did not represent the best value.
- Mechanical Counting – The protester argued the agency had simply counted the number of strengths and weaknesses without substantively evaluating whether they offset one another. GAO agreed. An evaluation rating must be based on more than a mechanical counting of strengths and weaknesses. Here, the agency had not explained how or why the strengths and weaknesses offset. Nor had the agency explained how it weighed the strengths and weaknesses to arrive at the acceptable rating. Without better documentation of the evaluation, GAO could not conclude the protester’s acceptable rating was reasonable.
- Best-Value Tradeoff – The protester also contended the tradeoff decision was inadequately documented. Again, GAO agreed. The sole rationale for the tradeoff analysis was the awardee’s better adjectival rating under the technical factor. But the agency had not discussed what the differences in technical ratings signified. The record did not indicate whether the agency had qualitatively compared quotations.
The protester is represented by Damien C. Specht, James A. Tucker, Alissandra Y. McCann, and Lyle F. Hedgecock of Morrison & Foerster LLP. The awardee is represented by Carla Weiss, Robert Nichols, and Logan Kemp of Nichols Liu, LLP. The agency is represented by Jose A. Figueroa of the Department of Energy. GAO attorneys Sarah T. Zaffina and Jennifer D. Westfall-McGrail participated in the decision.
–Case summary by Craig LaChance, Editor in Chief
