​Protest of Army Medical Center IT/VI services award dismissed

Protest of Army Medical Center IT/VI services award dismissed – June 19, 2017, GAO

“…The Army concluded that FreeAlliance’s proposal lacked an approach and “sufficient detail to demonstrate a clear understanding of the PWS. [FreeAlliance] provided evidence of available resources only of the LEAD IV Tech. This appears to be a staffing approach vs an understanding of the requirement.” AR, Tab 5, Technical Evaluation Report, at 2.

The protester acknowledges that its proposal for satisfying PWS § 3.4.2 “may have been a shorthand way to demonstrate understanding of the PWS.” Protest at 9. It argues, however, that because it proposed the incumbent staffer to perform the same tasks as sought in the PWS, the proposal “clearly provides the reasonable expectation of successful performance.” Protest at 10. FreeAlliance also points out that its proposal includes the resume of the incumbent staffer, which indicates that he has the skills necessary to satisfy the work requirements of PWS § 3.4.2. Id.

Based on this record, we find nothing unreasonable about the agency’s evaluation of FreeAlliance’s proposal under PWS § 3.4.2. FreeAlliance had the responsibility to submit an adequately written proposal that established the technical acceptability of its proposed approach. Verizon Fed. Inc, supra, at 4. Again, offerors were responsible for “address[ing] each work area in sufficient detail to demonstrate a clear understanding of the PWS.” RFP at 138. Rather than articulate an approach that addressed the work areas in PWS § 3.4.2, FreeAlliance only proposed a particular individual to staff the requirement. Even if the individual had the requisite skills to complete the different work areas, FreeAlliance’s proposal did not include a technical approach as to how it would address each of the work areas, as was expressly required by the solicitation. Accordingly, the agency reasonably found that FreeAlliance failed to propose an adequate technical approach to satisfy the requirements of PWS § 3.4.2.

In its comments on the agency report, FreeAlliance challenges the evaluation of its proposal under PWS § 3.4.2 on the basis that it interpreted the RFP to have “asked for a technician, not services.” Comments at 5, n.5. FreeAlliance further argues that the agency’s position that the RFP contemplated “services rather than staff is either a post hoc rationalization for departing from the terms of the Solicitation or an admission that the Solicitation was latently ambiguous to its needs.” Id. We find no merit to either allegation. The RFP expressly required…”

G2X TAKE: Sometimes having the incumbent staff on your team is not enough. A protest of this 5-year award to provide a range of IT and VI services in support of the Tripler Army Medical Center has been dismissed as GAO sided with the government award decision.

The rationale for the protest put forth by FreeAlliance appears to have fallen on deaf ears and the award to Kupono Government Services, LLC appears as if it will stand.

The important takeaway from this GAO decision is that having incumbent staff who are performing the duties today is not a substitute for showing “sufficient detail to demonstrate a clear understanding of the PWS” in the proposal response.The full decision document can be found above.

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