Lamar Strong Associates, LLC, B-407170, November 19, 2012

Link: GAO Decision

Protestor: Lamar Strong Associates, LLC

Agency: Department of the Army

Disposition: Protest Denied.

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GAO Digest:

Protest is denied where the agency reasonably concluded that the protester’s proposal was unacceptable and ineligible for award because it did not demonstrate that an individual proposed for a key personnel position had the experience required under the solicitation.

General Counsel PC Highlight:

Lamar Strong Associates, LLC (LSA) protested the award to Systems Kinetics Integration, Inc. (SKI) of a contract to provide subject matter expertise in information and tactical data systems, force modernization, equipment fielding processes, and information warfare, in support of the Office of the Deputy Chief of Staff for Programs. Proposals would be evaluated under technical, past performance, and price evaluation factors, with the technical factor having five equally-weighted subfactors. LSA was rated as unacceptable under the key personnel subfactor, based on the agency’s conclusion that the proposed individual did not meet the requirement to demonstrate a minimum of 10 years experience in contract management and managing force development related military duties.

The GAO found reasonable the agency’s determination that LSA’s proposal merited a deficiency under the key personnel subfactor and the overall technical factor because its proposed program/contract manager did not meet the minimum requirements for the position. The GAO rejected LSA’s interpretation of the RFP as allowing a combination of 10 years of contract management or management of force development. The GAO then declined to credit LSA’s proposed program/contract manager with additional experience based on several other work references. It noted that LSA’s proposal did not explain how tasks performed in these other positions, such as supervising or managing budgets, clearly related to contract management experience.

Offerors bear the burden of submitting well-written proposals that adequately address the requirements of the RFP. If an offeror proposes key personnel whose experience does not clearly fulfill the criteria of the RFP, the offeror should provide a detailed explanation relating the individual’s past work experience to the skills sought and tasks to be performed under the solicitation. The agency may consider less directly-related past performance if the offeror is able to demonstrate that the work performed is substantially similar to what that individual will be doing on the present contract.