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The Solicitation Didn’t Require a Price Realism Evaluation, But That Didn’t Stop the Protester from Challenging the Awardee’s Low Price

The protester argued that the awardee’s price was too low to adequately perform the contract. GAO dismissed. The protester’s argument was essentially a complaint about price realism. The solicitation, however, did not require a price realism assessment. 

Quadrant Training Solutions, JV, GAO B-422339 
  • Staffing and Wages – The awardee’s price was significantly lower than the protester’s. The protester alleged this low price was attributable to the awardee's insufficient staffing and low wages. The protester reasoned that the agency should have found the awardee’s staffing approach created technical risk. But GAO found this argument failed to state a valid protest basis. The solicitation did not require offerors to provide staffing of wages, nor did it indicate the agency would evaluate staffing and wages. 
  • Price Realism – The protester contended the awardee’s price was too low to perform the required work. GAO found this was effectively an argument that the agency failed to evaluate price realism. But the solicitation did not require the agency to evaluate price realism, so this argument also failed to state a valid protest basis. 

The protester is represented by J. Bradley Reaves, Beth V. McMahon, and Jacob D. Noe of Reaves GovCon Group. The awardee is represented by Matthew T. Schoonover, Matthew P. Moriarty, John M. Mattox II, Ian P. Patterson, and Timothy J. Laughlin of Schoonover & Moriarty LLC. The agency is represented by Colonel Christin Piper, Siobhan K. Donahue, and Michael V. Porter of the Air Force. GAO attorneys Uri R. Yoo and Alexander O. Levine participated in the decision. 

--Case summary by Craig LaChance, Editor in Chief 

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