Link: GAO Decision
Protestor: URS Federal Technical Services, Inc.
Agency: General Services Administration
Disposition: Protest Denied.
Protest of agency’s past experience and technical approach evaluations and source selection decision is denied where the record shows that the agency reasonably evaluated quotations consistent with the solicitation’s evaluation criteria.
General Counsel PC Highlight:
URS Federal Technical Services, Inc. protested the issuance to Systems Studies and Simulation, Inc. (S3) of a task order for flight training services for the Department of the Army’s 21st Cavalry Brigade at Fort Hood, Texas. Award was to be made on a best value basis, with non-price factors of past experience and technical approach, when combined, being significantly more important than price. Past experience was the most important factor, and vendors were required to demonstrate prior experience and specific training in seven critical areas. The RFQ indicated that past experience of proposed personnel would not be attributed to the firm’s past experience. The proposal evaluation team (PET) concluded that URS’s proposal was technically unacceptable because it fell short of the standards set forth in the PWS and the weaknesses and deficiencies identified would place the agency at high risk in meeting task order requirements.
The GAO first disagreed with URS that the agency’s evaluation of past experience was unreasonable, noting that URS failed to demonstrate HAMET experience for itself and that the agency is not required to infer information from an inadequately detailed proposal. The GAO then found that URS had not shown the agency’s evaluation of URS and S3’s technical approaches to be unreasonable. Finally, the GAO rejected URS’s objection to the award decision, pointing out that it was reasonable for the agency to decline to consider URS’s price on the grounds that the quotation had been properly determined to be technically unacceptable.
Vendors bear the burden of submitting adequately written quotations that comply with all requirements in the RFQ. Where the RFQ details specific areas in which vendors must demonstrate experience, vendors must ensure that they explicitly address each of those critical areas in their quotation. The agency has no obligation to infer experience on the basis of information contained elsewhere in the quotation, and vendors may be assessed weaknesses or deficiencies for failure to adequately address all aspects of the RFQ.