GAO Upholds Decision on Quantech's Bid Protest Against Air Force

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Quantech Services, Inc. recently lodged a bid protest against the Department of the Air Force's decision to award a task order to Tecolote Research, Inc. In their protest, Quantech alleges that the agency deviated from the established evaluation criteria outlined in the solicitation and conducted a flawed best-value tradeoff. However, the Government Accountability Office (GAO) has denied Quantech's claims, stating that the agency's evaluation was reasonable and consistent with the solicitation.

Background of the Task Order: Evaluation Criteria and Selection Process

The task order in question, issued on November 8, 2018, sought proposals for the provision of acquisition, strategic communication, and administrative support services. The evaluation of technical capabilities was the primary consideration in the agency's selection process, with the staffing matrix, flexibility, and staffing/retention/succession plan serving as the criteria.

Both Quantech and Tecolote received two strengths for their staffing matrix, but Quantech did not receive any strengths for the remaining criteria. Tecolote's proposal offered additional experience and presented an "exceptional process" to adapt to fluctuations in the government's needs. Additionally, Tecolote's staffing, retention, and succession plan were deemed thorough and met the requirements of the solicitation.

While the prices proposed by both offerors were found to be fair and reasonable, Quantech's bid was $3.1 million lower than Tecolote's. However, the source selection authority (SSA) determined that the price premium for Tecolote's proposal was justified by its greater technical capability. Tecolote's contingency plans for staffing fluctuations, along with access to a pool of 250 local personnel, made their proposal a superior choice in the eyes of the SSA.

Overview of Quantech's Protest and GAO Findings

Quantech raised several arguments in its protest but failed to adequately address the agency's responses, leading to the dismissal of its arguments. The GAO also found that the agency's technical evaluation was reasonable and consistent with the solicitation. Quantech contended that the agency should have evaluated individual staff members' qualifications rather than the combined qualifications of the proposed staff. However, the GAO sided with the agency, noting that Tecolote's proposed staff had significantly more years of experience, which was deemed an important factor in the decision-making process.

Quantech also disputed Tecolote's contingency staffing plan, arguing that it was hollow and merely relied on staff from other contracts. However, Quantech acknowledged that its own approach to contingency planning was practically identical. Again, the GAO found that the agency's consideration of the relative size of the pools from which Quantech and Tecolote could draw contingency staff was reasonable.

Conclusion

In summary, the GAO determined that the agency's evaluation was conducted in a manner consistent with the solicitation. The best-value tradeoff decision, which took into account Tecolote's proposed key personnel's additional years of experience and contingency staffing plans, was deemed reasonable. The GAO denied Quantech's protest and dismissed their allegations regarding Tecolote's ability to perform as proposed, as that falls under the purview of contract administration.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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