Protest alleging that a proposed task order for training services is outside of the scope of the underlying IDIQ contract is denied, where the contract provided for education products and general training support in addition to specific specialized training, and specifically stated that the agency’s options were not limited to training examples provided in the SOW.
People, Technology, and Processes LLC protested the Army’s decision to obtain training services for the Special Warfare Education Group under the Special Operations Forces Requirements, Analysis, Prototyping, Training, Operations, and Rehearsal III single-award IDIQ contract, arguing that the task order is beyond the scope of the SOF RAPTOR III contract.
USSOCOM informed PTP that it did not intend to exercise an option term under PTP’s existing task order, but instead intended to issue a task order for the required training services under SOF RAPTOR III. SOF RAPTOR III was competitively awarded to Raptor Training Services LLC, and provides for education and training support, among other areas. While the SOW provided examples of training services, it also stated that requirements could be unpredictable and that not every future task order could be articulated.
PTP argued that the proposed task order is outside the scope of SOF RAPTOR III, because the requirement involves baseline training for students with no knowledge of the subject matter. In contrast, PTP argued that SOF RAPTOR III focuses on operational training outside the doctrinal educational parameters and is designed for refinement of traditional occupational specialty skills. PTP argued that the specific training examples in the SOF RAPTOR III SOW are unrelated to the current requirement. PTP argued the examples focused on training support related to new technologies, which is a distinct category of training from current requirement, which involves assessing, selecting, and educating civil affairs, psychological operations, and special forces soldiers.
However, GAO found the scope of the SOF RAPTOR III contract is broad, and expressly contemplates the performance of general training for the special operations community. The SOW included the core competencies of “Education and Training Support,” and contemplated that the contractor will provide education products and general training support to the special operations community.
While the protester argued there is a difference between “doctrinal” and “operational” training, GAO found this unavailing. The SOF RAPTOR III contract does not use those terms in reference to training, does not appear to narrowly focus on operational training, and does not otherwise distinguish training on the basis of the trainee’s level of training or experience. While the protester correctly noted that the current requirement appears unrelated to some of the specific examples of training services in the SOW, GAO found it was not dissimilar to other examples. However, even assuming the protester was correct, GAO noted the SOW provided for general training support and notified offerors that other training services not defined in the SOW could be required. Accordingly, GAO had no basis to conclude that the task order fell outside the scope of SOF RAPTOR III, and denied the protest.
People, Technology and Processes LLC is represented by Victor L. Buonamia. The government is represented by Andrea K. R-Ferruli and Matthew Wilson, Department of the Army. GAO attorneys Michael Willems and Edward Goldstein participated in the preparation of the decision.
