Link: GAO Decision
Protestor: Sigmatech, Inc.
Agency: Department of the Army
Disposition: Protest Denied.
Protest challenging agency’s evaluation of the protester’s proposal and award determination is denied where the record demonstrates that the evaluation and source selection decision were reasonable and consistent with the solicitation’s evaluation criteria.
General Counsel PC Highlight:
Sigmatech, Inc. protested the issuance to CAS, Inc. of a task order for Lower Tier Project Office (LTPO) Missile Systems Independent Integration Analysis advisory and assistance services under the Army Aviation and Missile Command’s (AMCOM) Expedited Professional and Engineering Support Services (EXPRESS) Program. The RFP required vendors to identify a socio-economic status for themselves and for each subcontractor/team member used in the quotation. The solicitation and AMCOM EXPRESS BPAs permitted vendors to provide for a direct award to a small business team member. Although Sigmatech quoted a lower price, the SSA selected CAS as offering the best value to the government, finding that CAS was technically superior under the experience factor, with more experience directly related to the LTPO system program support.
The GAO found reasonable the agency’s evaluation of the vendors’ quotations under the experience factor, agreeing with the agency’s determination that Sigmatech did not demonstrate relevant experience with respect to 19 PWS requirements. The GAO noted that Sigmatech did not cite its quotation or explanation as to how it satisfied one of the PWS requirements with which it took issue when arguing that the agency failed to recognize its experience. The GAO also upheld the agency’s evaluation of CAS, finding reasonable the “outstanding” rating although CAS did not have directly related experience for 3 of the 132 PWS requirements. The GAO agreed with the agency that its evaluation of the socio-economic support factor was consistent with the RFQ, but noted that, even if it had found in favor of Sigmatech, this would not have impacted the source selection decision.
When objecting to the evaluation of proposals, a protestor should make clear and detailed arguments specifically referring to each aspect of the evaluation to which it objects. A protestor should explicitly reference the portions of its proposal that it believes satisfy the evaluation criteria, and present thorough reasoning behind each of its objections to the evaluation. However, every protestor must remember that, even where it can successfully challenge some portion of the evaluation, the protest may still be denied where those adjustments in the evaluation results are insufficient to lead to a different source selection.