Link: GAO Opinion
Agency: Department of the Army
Disposition: Protest denied.
Keywords: best value; tech eval
General Counsel P.C. Highlight:
GAO denied the protest of Exelis Systems Corporation, based on the issuance of a task order to L-3 Communications Vertex Aerospace, LLC, under a request for task order proposals (RFP), issued by the Department of the Army for logistics support services for the Fort Bragg Directorate of Logistics.
The solicitation contemplates the issuance of a cost-reimbursement task order to provide logistics support services for an 80-day phase-in period, one base year, and two one-year options on a “best value” basis, considering cost and two non-cost factors, mission capability and small business participation. The RFP further provided that the mission capability factor included three equally-weighted elements: (1) management approach; (2) staffing approach; and (3) technical experience.
Exelis asserted that the agency misevaluated L-3’s proposal under all three elements of the mission capability factor. First, in regards to the technical experience subfactor, GAO noted that the fact that L-3’s proposal did not specifically include technical experience information relating to each and every task or subtask enumerated in the RFP does not, standing alone, provide a basis for GAO to conclude that the agency’s evaluation was unreasonable. The RFP did not require offerors to demonstrate experience that correlated to every task of the PWS. Instead, the record showed that, consistent with the terms of the RFP, the agency performed an integrated assessment of the proposals, considering all three elements of the mission capability factor in arriving at its ultimate ratings. Therefore, GAO found no basis to object to the agency’s evaluation of this subfactor.
With regard to the management approach and staffing approach subfactors, GAO stated that because the RFP required the offerors to show how their proposed level of effort and staffing profile would meet the requirements of the solicitation, it necessarily contemplated that offerors could propose different technical approaches and manning to accomplish the work. Thus, merely because L-3 proposed staffing in particular areas that was different from that proposed by Exelis, did not, without more, show that L-3’s proposed staffing was inadequate. Rather, it showed only that L-3 and Exelis proposed different staffing. Also, even though L-3 may have proposed accomplishing the work with fewer personnel than proposed by Exelis, it does not follow that its manning is insufficient, or that its technical approach is deficient, for purposes of accomplishing the work contemplated by the RFP. The record showed that the Army evaluated L-3’s proposal under these two evaluation elements by reviewing the adequacy of L-3’s proposed staffing and management approach, and found that L-3’s proposal reflected a clear understanding of the RFP requirements and presented a feasible and comprehensive approach to performing the requirements.
Finally, Exelis challenged the Army’s source selection decision. According to the protester, the agency improperly failed to consider the magnitude of its technical superiority compared to what it describes as the modest cost premium associated with its proposal. However, GAO found that Exelis’ arguments amount to nothing more than a mere disagreement with the agency’s source selection decision, where the agency’s decision was found to be rational, adequately documented, and consistent with the terms of the RFP.