If a solicitation seeks experience peeling oranges, you can’t just tell the agency that you’ve eaten hundreds of oranges and assume that the agency will infer you peeled them. Rather, you have to explicitly tell the agency you’ve peeled oranges. You need to spell everything out, like that agency is an inexperienced child. Here, the solicitation required offerors to demonstrate multidisciplinary experience on a construction project. The protester described an HVAC project it worked on, assuming the agency would infer it was multidisciplinary. Alas, the agency did not make that inference. GAO said that the protester had to demonstrate its multidisciplinary experience and could not expect the agency to infer it.
MIG Construction Partners, GAO B-419818.4, B-419818.9
Background
The Navy issued a solicitation seeking proposals for design and build construction services. The solicitation required offerors to submit a previous completed multidisciplinary design-bid-build project.
MIG Construction Partner submitted a proposal. The Navy, however, found MIG’s proposal unacceptable because the design-bid-build project it listed was not multi-disciplinary; it only included one discipline—HVAC work. MIG protested, arguing that it had included enough information in its proposal to demonstrate a multidisciplinary project.
Legal Analysis
MIG had listed a project involving HVAC replacement. MIG reasoned that the HVAC entailed multiple disciplines, such as electrical work. MIG believed that the multidisciplinary nature of the work could be inferred from its description of the project.
GAO didn’t agree. An offeror must submit a well-written proposal. Here, MIG’s description of its project focused only on mechanical repair. While the proposal stated that the project had involved multiple disciplines, it did not clearly demonstrate what those disciplines were. The Navy had reasonably rejected the proposal.
MIG is represented by Beth V. McMahon of ReavesColey, PLLC. The agency is represented by Ann L. Gidding and Kyle Symanowitz of the Navy. GAO attorneys Michael P. Price and John Sorrenti participated in the preparation of the decision.
