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The protester complained that the evaluators identified a strength in its proposal, but the agency removed the strength for the overall report. GAO denied, reasoning it’s common for individual evaluations to differ from the overall consensus evaluation.
Management and Technical Services Alliance Joint Venture, GAO B-422786; B-422786.2, B-422786.3
- Technical Proposal – The protester challenged the award of a task order for program support services in management offices. The protester claimed the agency failed to identify multiple strengths in its proposal for features that exceeded the RFP’s requirements. Notably, members of the technical evaluation team (TET) identified strengths in the proposal, but the agency “removed” them in the TET report. GAO didn’t see a problem. It is common for individual evaluator ratings to differ from the consensus rating eventually assigned and therefore denied the allegation.
- Awardee’s Past Performance – The protester argued the agency should have excluded two of the awardee’s past performance references because the awardee failed to provide a past performance questionnaire (PPQ) for those references. GAO acknowledged the solicitation required offerors to provide a PPQ for each reference but also recognized that the agency provided conflicting responses during the question and answer (Q&A). Based on this, GAO found the solicitation patently ambiguous. However, because patent ambiguity must be challenged before submission of proposals, GAO rejected the protester’s argument.
- Protester’s Past Performance – The protester claimed its references were nearly identical to the instant task order, yet the agency found that they did not involve the same scope and magnitude as the RFP. The protester submitted three past performance references, two of which were predecessor task orders to the instant requirement. The evaluators had found, and GAO left undisturbed, that despite including some of the same tasks as the RFP, the protester’s references did not reflect experience with logistics design, training services, security, and integrated support.
The protester was represented by Stephen R. Ramaley, Adam A. Bartolanzo, Lauren S. Fleming, and Cash W. Carter of Miles & Stockbridge P.C.. The intervenor was represented by Paul Hawkins, J. Bradley Reaves, and Jacob Noe of Reaves GovCon Group. The agency was represented by Mark Wisniewski and Gabriel D. Soll of DHS. Michelle Litteken and Christina Sklarew of GAO participated in the preparation of the decision.
— Case summary by Joshua Lim, Assistant Editor
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