Link: GAO Decision
Protestor: SGT, Inc.
Agency: National Aeronautics and Space Administration
Disposition: Protest Denied.
- Protest that agency misevaluated awardee’s proposal is denied where record shows that agency’s evaluation was reasonable and consistent with the solicitation’s evaluation scheme.
- Protest that agency disparately evaluated awardee’s and protester’s proposals is denied where record shows that there were legitimate reasons to distinguish between the proposals.
- Protest alleging that agency’s source selection decision was improper is denied where record shows that agency performed a thorough, integrated assessment of the comparative merits of protester’s and awardee’s proposals and identified a reasonable basis for its award decision.
General Counsel PC Highlight:
SGT, Inc. protested the award to Honeywell Technology Solutions, Inc. of a contract for ground systems and mission operations services at Goddard Space Flight Center. Although Honeywell’s proposed cost was $33.4 million higher than SGT, the source selection authority (SSA) concluded that Honeywell offered the best value to the government. After its debriefing, SGT brought several concerns to the agency’s attention, including the assignment of a weakness to SGT’s proposal in the area of flight dynamics integration; the agency agreed to hold open SGT’s debriefing while it reviewed the matters raised. The agency revised its scoring and narrative materials to eliminate the weakness and assign the proposal an additional 3.75 points; these findings were presented to the SSA, who prepared an addendum to his original source selection statement. The SSA ultimately concluded, however, that Honeywell continued to offer the best value to the government and made award accordingly.
The GAO found no merit to SGT’s assertion that Honeywell failed to fulfill a material solicitation requirement for lacking a required CMMI-DEV rating, pointing out that the RFP merely required that offerors include a quality assurance plan, and that the plan describe the relationship to any other corporate process initiatives (such as CMMI) that are planned or currently underway. The CMMI-DEV requirement only applied to the contractor, not all offerors, and Honeywell had a largely acceptable plan that would enable it to obtain the appropriate rating. The GAO also disagreed with SGT that the agency had evaluated proposals disparately, finding each of SGT’s assertions to be nothing more than disagreement with the agency’s evaluation conclusions. Finally, the GAO rejected SGT’s complaints regarding the cost/technical tradeoff, noting that, while SGT’s proposal received a slightly higher technical score under the mission suitability factor, the SSA specifically concluded that the Honeywell proposal was technically superior.
Disappointed offerors must remember that point scores assigned during evaluation are merely guides to assist the SSA in making an intelligent award. The fact that one proposal receives a slightly higher numerical score is immaterial when the SSA is making an integrated and thorough assessment of the proposals in all areas. The SSA may reach a different conclusion than lower-level evaluators, and the GAO is unlikely to sustain the protest so long as the SSA’s conclusion is adequately supported by the record.