Protest challenging the agency’s best-value source selection decision is sustained, where the source selection decision relied on a recitation of the evaluation ratings, without any meaningful analysis of the differences between the offerors’ proposals or a substantive explanation of why the protester’s superior technical proposal did not warrant a price premium.
ManTech Advanced Systems International Inc. protested the Defense Intelligence Agency’s award of a task order to develop and enhance enterprise applications to The Buffalo Group, arguing that the source selection decision was flawed.
Although the agency evaluators and source selection authority acknowledged that ManTech’s technical proposal was superior to the awardee’s and posed a very low risk of unsuccessful performance, the SSA concluded that ManTech’s offer was not work the nearly $75 million price premium.
In its protest, ManTech argued that the determination that the awardee’s proposal represented the best value was inconsistent with the RFP’s evaluation criteria, which elevated technical/management approach above price, and required a tradeoff, rather than an award to the lowest-priced, technically acceptable offeror. ManTech also argued the agency failed to explain why its technically superior approach did not merit the additional cost.
In response, DIA suggested that ManTech merely disagreed with its judgment and argued that there is no need for extensive documentation of every consideration factored into a tradeoff decision.
However, GAO found the record contained no meaningful comparison of the proposals or an explanation stating why ManTech’s significantly higher technically rated proposal was not worth the price premium. For example, under the program objectives factor, the awardee was rated as adequate for each of the eight objectives, while ManTech was assigned two strengths and rated adequate for the remaining objectives. While the SSA concluded that ManTech’s proposal was slightly technically superior to The Buffalo Group’s proposal with regard to the program objectives factor, the record contained no qualitative comparison or explanation beyond the recitation of ratings.
Under the most important factor, the technical/management evaluation factor, the awardee was rated adequate for six elements and received one strength. In contrast, ManTech’s proposal received six strengths and one significant strength. However, the SSA again concluded that ManTech’s proposal was technically superior to the awardee’s without any qualitative comparison or explanation beyond these ratings.
Similarly, while the tradeoff decision provided a brief recitation of each offerors’ strengths, there was no substantive comparison or analysis of the offerors’ proposals or the rationale for determining why ManTech’s higher-rated proposal was not worth its price premium. Instead the SSA noted a “considerable distinction between technical proposals” without providing a substantive analysis. According to GAO, such a general statement falls far short of the requirement to justify cost/technical tradeoff decisions, especially in the presence of significant qualitative differences between the two proposals.
ManTech Advanced Systems International Inc. is represented by Paul F. Khoury and Samantha S. Lee of Wiley Rein LLP. The Buffalo Group is represented by David A. Edelstein, Allison Geewax, Laurence Schor, and Tamara M. McNulty of Asmar, Schor & McKenna, PLLC. The government is represented by Jessica A. Easton, Lieutenant Colonel Gregory J. Fike, Douglas Francken, Max D. Houtz, and Gregory A. Moritz, Defense Intelligence Agency. GAO attorneys Katherine I. Riback, and Amy B. Pereira participated in the preparation of the decision.
