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Protester Said Its Incumbency Should Have Turned Strengths into Significant Strengths. GAO Didn’t See It that Way.

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The protester argued its status as an incumbent should have turned a single strength into two significant strengths. GAO rejected the protester’s analysis, finding the argument was simply disagreement with the agency’s evaluation conclusions. 

Gemini Tech Services, LLC GAO B-421911, B-421911.2 
  • Transition Plan Strength – The agency assigned the protester a strength for its retention of employees and its recruitment of qualified candidates. The protester argued its status as an incumbent should have transferred this single strength into two significant strengths: one for retention of staff and one for identification of new personnel. GAO disagreed. An offeror is not entitled to extra credit for its incumbent status. Moreover, the agency reasonably concluded the protester’s retention and recruitment plan merited a strength. The protester's argument amounted to disagreement with the agency. 
  • Outstanding v. Good Rating – The agency assigned the protester’s technical proposal a “good” rating. The protester argued that based on the number of strengths received, it should have received an outstanding rating. Again, GAO found this argument amounted to disagreement with the agency. Adjectival ratings are merely guides. GAO generally does not worry much about adjectival ratings. Rather, GAO' concern is whether the underlying evaluation wass reasonable. Here, the evaluation was reasonable. GAO saw no reason to quibble with adjectival ratings. 

The protester is represented by Matthew T. Schoonover, Matthew P. Moriarty, John M. Mattox, II, Ian P. Patterson, and Timothy Laughlin of Schoonover & Moriarty, LLC. The agency is represented by Wade L. Brown and Kenneth Gilliland of the Army. GAO attorneys Suresh B. Boodram and Nathaniel S. Canfield, and Evan D. Wesser participated in the decision. 

--Case summary by Craig LaChance, Senior Editor 

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