The protester argued the awardee violated formatting requirements by using charts, graphs, and tables to squeeze additional narrative text into its proposal. GAO didn’t find the argument compelling. Nothing in the solicitation prohibited offerors from including narrative text in tables, charts, and graphs.
Assessment and Training Solutions Consulting Corporation, GAO B-421575.3, B-421575.4
- Table, Charts, and Figures – The protester argued the awardee violated a limitation on the use of tables, charts, and graphs. The solicitation allowed a small font size for tables, charts, and graphs. But the protester argued the awardee’s tables and graphs contained extensive narrative text that should have been included in a larger font in the main text of the proposal. GAO rejected the argument. The solicitation did not limit the use of narrative text in tables, charts, and graphs. Conversely, the solicitation did not state that tables, charts, and graphs could only contain supplemental information.
- Heading Font – The protester also argued that while the solicitation required that the proposal’s main text be in 12-point font, the awardee’s headings had been in a smaller font. GAO agreed that the awardee’s headings used a smaller font. Nevertheless, the protester had not shown how it had been prejudiced by this small font. It did not show that the agency relied on the information in this smaller font in making in making the award decision.
- Significant Strengths – The protester argued that many of the strengths assigned to its proposal should have been significant strengths. But GAO found the protester merely objected to the weight the agency assigned to its advantages. This was mere disagreement with the agency’s evaluation conclusions.
- Additional Strengths – The protester alleged its proposal should have received additional strengths. GAO found that most of these arguments were essentially a request that the agency give it more credit for its performance on the incumbent contract. There is no requirement that an agency give an offeror extra credit for its status as an incumbent.
- Past Performance – The protester argued the agency did not perform a holistic past performance evaluation. Instead, the protester contended, the agency haphazardly based the evaluation on past performance questionnaires. GAO didn’t see a problem. Again, the protester’s arguments amounted to disagreement with the agency’s conclusions.
The protester is represented by Jeremy S. Scholtes, Roger V. Abbott, and Lauren S. Fleming of Miles & Stockbridge P.C. The awardee is represented by Ryan C. Bradel and Michael E. Hatch of Ward & Berry, PLLC. The agency is represented by Sandy L. Caruco, Erin F. Masini, and Joseph Anzalone of the Central Intelligence Agency. GAO attorneys Samantha S. Lee and Peter H. Tran participated in the decision.
–Case summary by Craig LaChance, Editor in Chief
