As everyone learned high school, when writing fiction or non-fiction, you must strive to “show not tell.” This means if you’re writing about someone who’s sad, don’t just say, “He was sad.” Instead, say something like, “He sobbed uncontrollably, ululating like an Old World widow.” As this GAO decision illustrates, the show don’t tell rule also applies to proposal writing. If a solicitation says “Offerors must have experience doing X.” Don’t just spit this back by stating “I have experience doing X.” Rather, your proposal should show, through examples, your experience doing X.
Resource Management Concepts, Inc., GAO B-421320
Background
The Navy issued an RFP to small business holders of the SeaPort NextGen IDIQ contract. The RFP sought support for Navy sensor systems. Two offerors, Resource Management Concepts (RMC) and Solutions Development Corporation (SDC), submitted proposals. The Navy selected SDC’s higher-rated proposal. RMC protested.
Analysis
Restating Requirements
RMC objected to weaknesses it received under the technical factor. The Navy assessed weaknesses because it thought RMC had not demonstrated an understanding or ability to perform the required tasks. RMC argued its proposal demonstrated its understanding.
GAO sided with the agency. In many cases, RMC had simply restated solicitation requirements. Simply reciting solicitation requirements, without more, does not demonstrate an understanding of requirements.
Unstated Criteria
RMC argued the Navy applied unstated criteria when it assessed a significant weakness for lacking program planning and budgeting. RMS argued the words “program planning and budgeting” did not exist in the solicitation.
GAO concluded the Navy had not applied unstated criteria. The solicitation stated in multiple places the Navy needed “program and financial analysis.” It was not unreasonable for the Navy to want to see a discussion of cost and budgeting from offerors.
Key Personnel
RMC complained about a weakness assessed to key personnel. The solicitation required a program manager with five years of contract management experience. The Navy assessed a weakness because RMC’s program manager only had two years of experience as a program manager. RMC claimed the Navy was conflating program management experience with contract management. While its program manager only had five years of experience of program management, he had over five years of experience with contract management.
But the Navy reasonably assessed the weakness. The solicitation required a program manager with five years of contract management experience. Contract management experience was not enough. Rather, the contract management experience had to be obtained as a program manager.
RMC is represented by Edward J. Tolchin of Offit Kurman, P.A. The intervenor, SDC, is represented by James N. Rhodes, Katherine B. Burrows, Patrick T. Rothwell, and Jonathan W. Williams of PilieroMazza PLLC. The agency is represented by Theresa A. Cortese-Fusaro and Nikki Musick of the Navy. GAO attorneys Hannah G. Barnes and Christina Sklarew participated in the decision.
–Case summary by Craig LaChance, Senior Editor
