Booz Allen Hamilton, Inc. (B-422823; B-422823.2)

Category: Technical evaluation, cost or price evaluation, best-value tradeoff

Date: 18 November 2024

URL: https://www.gao.gov/products/b-422823%2Cb-422823.2

You should not care.

Booz Allen Hamilton, Inc. (BAH), protested VA's award of a task order for enterprise software development services to Deloitte Consulting, LLP, under GSA Alliant II. BAH argued that the VA improperly evaluated Deloitte’s proposal and failed to conduct a reasonable best-value tradeoff. The protest was denied.

BAH contended that Deloitte’s proposal demonstrated deficiencies in staffing and recruitment strategies, which BAH argued were exacerbated by Deloitte’s low labor rates, posing a performance risk. BAH also claimed that the VA downplayed weaknesses in Deloitte’s approach, while inadequately considering the superior technical merits of BAH’s proposal.

GAO determined that VA’s evaluation was reasonable and consistent with the solicitation’s terms. While Deloitte’s proposal included weaknesses, these were deemed minor and not indicative of significant performance risks. Notably, the solicitation did not require a price realism analysis, so the VA was not obligated to evaluate whether Deloitte’s lower price could sustain its technical approach. GAO emphasized that VA conducted a comprehensive evaluation, considering both proposals’ technical merits and costs.

Ultimately, VA selected Deloitte’s technically acceptable proposal, which met all requirements, over BAH’s technically superior but significantly more expensive bid (89% price premium). GAO affirmed the agency’s decision, highlighting that a lower-priced proposal could reasonably be chosen when the higher-rated proposal’s benefits did not justify the price premium.

Agencies have broad discretion in making tradeoff decisions. Even when technical factors are weighted most heavily, agencies are not obligated to select a higher-priced proposal if the additional cost cannot be justified. Contractors should consider the balance of technical excellence and price competitiveness in their bids.

Digest

Protest challenging the agency’s evaluation of proposals and best-value tradeoff is denied where the agency’s evaluation and tradeoff were reasonable and consistent with the terms of the solicitation and applicable procurement law.