The protester complained that the agency had wrongly penalized it for not sufficiently detailing its approach. The protester argued the solicitation’s page limitations precluded it from detailing its approach. GAO rejected the protester’s argument. The problem was not the page limitations. Rather, the protester had submitted a poorly-written proposal that focused too much on past experience without connecting that experience to the solicitation’s objectives.
iSenpai, LLC, GAO B-421123
Background
The Air Force posted an RFQ for software development security. The RFQ provided for three-step evaluation process. In the first phase, the Air Force would review quotations for compliance with the RFQ. In the second phase, the Air Force would evaluate quotations for technical capability. Only quotations rated as “highly capable” would be allowed to participate in the third, oral presentation phase.
iSenpai submitted a quotation in response to the RFQ. But iSenpai didn’t receive a “highly capable” rating under the technical capability factor and thus was not invited to the third phase. iSenpai protested.
Analysis
Understanding of Statement of Objectives
The Air Force had rated iSenpai as merely capable because the agency determined that iSenpai’s quotation didn’t include details of how the company would commit to the work stated in the RFQ’s Statement of Objectives (SOO). iSenpai had included a broad overview of its past experience, but it had not connected that experience to the SOO. iSenpai argued that it was precluded from providing additional detail by the RFQ’s page limitations.
GAO did not find page limit argument compelling. The problem was that iSenpai had not submitted a well-written proposal. It had spent too much space describing its past experience without detailing how it planned to approach the objectives of the RFQ.
Unstated Criteria
iSenpai alleged the Air Force had applied unstated criteria in penalizing the company for not providing details on how it would provide personnel within 10 days. iSenpai reasoned that RFQ did not require vendors to provide personnel within 10 days.
GAO disagreed with iSenpai. The RFQ provided that the contractor must provide qualified manpower within ten days of a vacancy. The Air Force had not applied unstated criteria in holding iSenpai to a ten-day timeline.
iSenpai is represented by Shane J. McCall, Nicole D. Pottroff, John L. Holtz, Stephanie L. Ellis, and Gregory P. Weber of Koprince McCall Pottroff LLP. The agency is represented by Colonel Frank Yoon, Major Ashley M. Ruhe, Major Alissa J. Schrider, and Laura L. Atkinson of the Air Force. GAO attorneys Samantha S. Lee and Peter H. Tran participated in the preparation of the decision.
–Case summary by Craig LaChance, Senior Editor
