Link: GAO Opinion
Agency: Department of the Army
Disposition: Protest denied.
General Counsel P.C. Highlight:
GAO denies the protest of Caduceus Healthcare, Inc., based on the rejection of its proposal as unacceptable under a request for proposals (RFP), issued by the Department of the Army, for medical services. Caduceus challenges the agency’s technical evaluation of its proposal.
GAO denied the protest where Caduceus had offered in its proposal only “vague references” to its documentation maintenance processes and procedures, and GAO concluded that Caduceus is merely disagreeing with the agency’s evaluation. Such disagreement, stated GAO, is not sufficient to show that the evaluation was unreasonable. Additionally, GAO did not find that the Army used unstated evaluation criteria in evaluating Caduceus’s proposal, as Caduceus argued. GAO stated that “[a]lthough agencies are required to identify in a solicitation all major evaluation factors, they are not required to identify all areas of each factor that might be taken into account in an evaluation, provided that the unidentified areas are reasonably related to or encompassed by the stated factors.” GAO found that the “unstated evaluation criteria” alleged by the protester were reasonably encompassed within the stated factors within the RFP.