The protester argued the agency did not conduct a proper cost realism analysis because it didn’t compare the awardee’s proposed costs to any meaningful source of data. GAO denied. The only other “meaningful source of data” was the protester’s proposed costs or the incumbent costs. GAO found the solicitation did not require the agency to compare the awardee’s rates to the protester’s or incumbent’s rates.
CACI, Inc.–Federal, GAO B-422774; B-422774.2
- Solicitation– The agency issued a task order for scientific engineering, technical, and analytical support services. The protester received an overall higher rating than the awardee in the agency’s evaluation. However, the agency found the awardee’s cheaper evaluated cost to be worth the tradeoff. The protester challenged multiple aspects of the agency’s evaluation.
- Cost Realism – The protester argued the agency unreasonably failed to recognize the awardee’s unrealistically low labor costs. The protester contended the agency failed to compare the labor rates to any meaningful source of data other than the awardee’s data. GAO observed that the protester essentially wanted the agency to compare the awardee’s rates to the protester’s rates or the incumbent rates. GAO ruled that this was not required. The agency reasonably assessed the realism under the solicitation.
- Personnel Approach – The protester maintained that the agency failed to evaluate the awardee’s non-key personnel per the solicitation. The agency responded that the protester misinterpreted the different solicitation requirements for key and non-key personnel and that the awardee complied with the solicitation. After reading the solicitation terms, GAO concluded the solicitation required offerors to propose key personnel information while permitting non-key personnel information. Furthermore, the protester’s interpretation of requiring the agency to assess the qualification of every non-key personnel conflicted with the other sections of the RFP.
- Reasonable Evaluation – The protester contended that if the agency evaluated the awardee’s staffing plan, it would have found the proposal was deficient and unacceptable due to underqualified personnel. GAO found this was based on an unreasonable interpretation of the solicitation and an incomplete reading of the awardee’s proposal. Thus, GAO denied the protest overall and deemed the best-value tradeoff reasonable.
The protester was represented by Robert K. Tompkins, Gordon N. Griffin, Hillary J. Freund, Richard J. Ariel, Kelsey M. Hayes, and Tanner N. Slaughter of Holland & Knight LLP. The intervenor was represented by Daniel R. Forman, James G. Peyster, and Roxanne N. Cassidy of Crowell & Moring LLP. The agency was represented by Jeanne P. Ockerman, Rhonda L. Russ, and Patrick C. Sheehan of the Navy. Heather Self and Peter H. Tran of GAO participated in the preparation of the decision.
— Case summary by Joshua Lim, Assistant Editor
