The protester contended it should have received credit for proposing personnel positions that were not required by the solicitation but that nonetheless benefitted the agency. GAO wasn’t convinced, finding the protester had not provided any details as to the purported benefits of this novel staffing approach.
VMD Systems Integrators, Inc., GAO B-421197
Background
The Department of Agriculture’s Natural Resources Conservation Service (NRCS) issued a solicitation to holders of the National Institute of Health’s CIO-SP3-SB-8(a) IDIQ contract. The solicitation sought information technology services. After reviewing proposals, NRCS awarded a task order to At-Impact, LLC. An unsuccessful offeror, VMD Systems Integrators, protested.
Analysis
Prior Experience
VMD contended NRCS failed to acknowledge beneficial aspects of its proposal that should’ve have increased agency confidence under the prior experience factor. GAO, however, found that the agency had credited VMD for these beneficial aspects.
Staffing Benefit
VMD further alleged NRCS failed to credit its proposal for filling personnel positions that were not required by the solicitation, but which benefited the agency. GAO found that VMD had not provided any detail on the purported benefit of these positions. GAO saw no basis to conclude the agency unreasonably failed to credit VMD for these benefits.
Lack of Detail
VMD complained the agency had improperly penalized its proposal for a lack of detail. GAO found that VMD’s claims relied on post hoc arguments or required the agency to piece together details from other parts of the proposal. GAO reasoned that VMD’s complaints were not based on the content of the company’s proposal but rather what VMD contended was the intention of its proposal.
VMD is represented by Damien C. Specht, James A. Tucker, and Victoria Dalcourt Angle of Morrison & Foerster LLP. The intervenor, At-Impact, is represented by Richard J. Webber, Travis L. Mullaney, and Patrice Z. Howard of the ArentFox Schiff LLP. The agency is represented by Elin M. Dugan of the Department of Agriculture. GAO attorneys Nathaniel S. Canfield and Evan D. Wesser participated in the preparation of the decision.
–Case summary by Craig LaChance, Senior Editor
