Link: GAO Opinion
Agency: General Services Administration
Disposition: Protest denied.
General Counsel P.C. Highlight:
GAO denied the protest of Lockheed Martin Integrated Systems, Inc., regarding the issuance of a task order to L-3 Services, Inc., under a task order request (TOR) issued by the General Services Administration (GSA), Federal Systems Integration and Management Center, to procure, on behalf of the Department of the Army, Program Executive Office (PEO) Enterprise Information Systems (EIS), various information technology (IT) technical support services for Reserve Component Automation (RCA).
The TOR provided for the issuance of a hybrid fixed-price/cost-plus-award-fee task order for a base year and four option years. The TOR provided that award would be made based on technical approach, key personnel and project staffing, management approach, past performance, and price. After finding a total of 20 strengths and five weaknesses in L-3’s proposal and 11 strengths and 17 weaknesses in Lockheed’s proposal, award was made to L-3.
Lockheed generally argues against the selection of L-3’s higher-rated, higher-cost proposal. Lockheed first argues that the agency unequally and disparately evaluated both proposals with respect to the proposed SLA metrics, on which the award fee would in part be based. The firms were directed to submit comprehensive, detailed, and relevant SLAs and performance metrics. GAO stated that Lockheed had no argument that the agency was unfair in its evaluation where the record showed that the agency reasonably evaluated both firm’s SLA approaches. Even though Lockheed felt that its SLA metrics were more stringent than those proposed by L-3, GAO found that the argument was without merit. L-3 proposed a greater number of more stringent and more detailed SLAs than Lockheed and L-3’s proposal offered more value to the agency.
Lockheed next challenged four weaknesses in its proposal under the technical approach and project staffing, and management approach evaluation factors. However, GAO concluded that Lockheed failed to demonstrate that the weaknesses impacted the agency’s tradeoff decision.
Lockheed challenged the agency’s cost/technical tradeoff decision, stating that the SSA’s reliance on features in L-3’s proposal tainted the tradeoff analysis. GAO concluded that the agency’s decision was reasonable and consistent with the solicitation’s evaluation criteria and was documented. The record demonstrated that the SSA reviewed all of the evaluation criteria, recognized each strength and weakness of each firm, and identified all advantages offered by L-3.