Link: GAO Opinion
Agency: Department of Homeland Security
Disposition: Protest denied.
General Counsel P.C. Highlight:
GAO denied the protest of e-Management, based on the exclusion of its proposal from the competitive range under a request for proposals (RFP) issued by the Department of Homeland Security, United States Citizenship and Immigration Services (USCIS), for enterprise architecture services and governance planning.
The RFP was issued to offerors holding 8(a) Streamlined Technology Application Resource for Services (STARS) II government-wide acquisition contracts. Offerors were required to have one or more industry credentials. Offerors were informed that they were required to have at least an International Organization for Standardization (ISO) 9001-2000 or higher certification. The agency also responded to a question concerning whether the agency would accept a different credential in the negative.
e-Management, after its proposal was excluded from competitive range, argues that the requirement for the ISO 9001-2000 certification could be satisfied by a subcontractor. However, GAO found that the record showed that the agency reasonably evaluated e-Management’s proposal in accordance with the solicitation where it was made clear that the prime contractor must have the requisite certification and e-Management failed to meet that requirement.