Link: GAO Opinion
Agency: Department of the Army
Disposition: Protest denied.
General Counsel P.C. Highlight:
GAO denied the protest of Honeywell Technology Solutions, Inc. (HTSI), based on the Department of the Army, Army Materiel Command’s, amendment of a request for proposals (RFP), for integrated logistics support services (ILSS-2).
The RFP was for the award of three contracts to provide logistics support, property accountability services, and maintenance. Award was to be made based on the following evaluation factors: technical; past performance; price; and small business participation. Past performance was to be evaluated “to determine how relevant a recent effort accomplished by the Offeror is to the ILSS-2 mission utilizing the relevancy ratings.”
HTSI argues that the minimum requirements for past performance for determining relevance do not represent the actual or comparable levels of size, magnitude of effort, or complexity as those of the incumbent contracts performed by HTSI or those in the solicitation. The RFP required that for a contract to be relevant, it must be one for providing property accountability services (scope) and involve a certain minimum level of complexity (either 500 transactions a week, or support at three or more locations). In addition, it must involve a minimum magnitude meaning a minimum magnitude of either a $20 million contract for one year, 200 hand receipts for one year, or 100 employees. HTSI argues that the numbers should be higher. However, GAO disagreed, stating that the agency did not abuse its discretion in setting such relevance requirements based on the agency’s experience. GAO also noted that there is no requirement that an agency base its determination of relevance on the same levels of scope, magnitude, and complexity as those under the incumbent contracts.