The solicitation said the agency would select the quotation that provided the “best value.”The protester said this required a tradeoff. GAO disagreed. Best value simply means the greatest overall benefit. Nothing about the phrase requires an agency to weigh factors and make a tradeoff.
Export 220Volt, Inc., GAO B-422216
- Best Value – The protester challenged the award. The protester argued the agency had not followed the solicitation’s award methodology. The solicitation stated award would be made to the quote that represents the best value to the government. The protester argued this required the agency to conduct a best-value tradeoff. The agency, however, had made award on a lowest-price, technically acceptable basis.
- Solicitation Did Not Require a Tradeoff – The solicitation may have used the words “best value,” but GAO said this didn’t require a tradeoff. The FAR simply defines “best value” as an outcome that provides the greatest overall benefit to the government. An agency can obtain the best value from a variety of methodologies. Indeed, the FAR identifies LPTA as part of the “best value” continuum. Notably, the solicitation did not identify any factors other than price the agency had to evaluate. Nor did it identify the weight the agency would give to other factors. Nothing in the solicitation required a tradeoff. The LPTA methodology was acceptable.
The protester is represented by Paula K. Thakkar. Trevor Davies of the Navy represents the agency. GAO attorneys Emily R. O’Hara and Peter H. Tran participated in the decision.
--Case summary by Craig LaChance, Senior Editor