Link: GAO Opinion
Agency: Department of Justice
Disposition: Protest denied.
Keywords: Blanket purchase order; Key personnel; Resumes
General Counsel P.C. Highlight: It is the offeror’s obligation to insure that all resumes submitted in response to an RFQ are responsive to the Government’s requests.
After issuing a request for quotations (RFQ) to establish a blanket purchase agreement (BPA) for conference planning and logistical support services, the Department of Justice received several proposals. One of the unsuccessful bidders was Palladian Partners, Inc., who protested the decision by asserting that the Department of Justice had misevaluated its quotation by assigning it an unacceptable rating under the key personnel/professional staff factor. This factor was one of the six upon which the “best value” selection was to be based.
According to the terms of the RFQ, certain key personnel posts had to meet specific requirements based on years of experience, levels of education, and amount of training or certification. Three of the six resumes that Palladian submitted for this evaluation factor were found to be lacking by the agency for not possessing the requisite amount of years of experience, nor the level of required education.
In its review of the protest, GAO examined the record to determine whether the agency’s evaluation was reasonable and consistent with the terms of the solicitation and applicable procurement laws and regulations. Based on this examination, GAO determined that the Department of Justice’s evaluation was reasonable and followed the terms of the RFQ. In particular, GAO found that the resumes submitted by Palladian in support of the key personnel factor were vague, lacking in detail, or did not comply with the terms of the RFQ on their face. Accordingly, Palladian’s protest was denied.