GovCIO, LLC (B-421290.6; B-421290.7; B-421290.8)
Category: Technical evaluation, past performance, discussions, process issue, IDIQ
Date: September 11, 2024
URL: https://www.gao.gov/products/b-421290.6%2Cb-421290.7%2Cb-421290.8
You should care.
GovCIO LLC protested VA’s award of a file conversion services task order to General Dynamics Information Technology (GDIT) under the Veterans Intake, Conversion, and Communication Services (VICCS) IDIQ.
VA’s RFQ required bidders to show the capacity to handle an estimated daily workload of 1.2 million documents. GovCIO claimed that VA’s assessment of GDIT’s technical proposal was flawed, alleging an exaggerated interpretation of GDIT’s stated conversion capabilities. This inflated assessment contributed to VA’s choice of GDIT’s more costly bid .
GDIT proposed a capability to convert approximately 1.7 million documents per day, calculated on a workday basis (252 days per year), which exceeded the agency’s minimum requirement. However, VA calculated the 1.2 million daily requirement over calendar days (365 days per year). When comparing GDIT’s capacity calculated by workday against VA’s calendar-day requirement, VA overstated GDIT’s capacity by around 41%, erroneously awarding it a significant strength used to justify GDIT’s $86 million price premium.
GAO sustained on this point, concluding that VA’s error could have materially impacted the best-value tradeoff decision.
GovCIO’s protest also argued VA mishandled past performance evaluations and discussions. VA rated GovCIO “neutral” in past performance, finding GovCIO’s references lacked relevance in scope and contract value compared to the current requirement. GAO upheld this evaluation, stating VA’s approach aligned with solicitation criteria. Additionally, GovCIO argued that during discussions, VA should have flagged this rating, but GAO ruled that such disclosure was unnecessary as a neutral past performance rating is not considered a deficiency.
GAO also dismissed GovCIO’s argument that VA should have reassessed GDIT’s responsibility owing to its alleged anticompetitive behavior; GAO noted IDIQ task orders do not require additional responsibility determinations.
This decision highlights the need for precision in technical evaluations, particularly when using metrics that compare offerors’ capabilities against agency requirements. Inflated assessments based on misaligned calculations can improperly skew best-value determinations, leading to potentially costly misjudgments.
Digest
Protest challenging agency’s assessment of a significant strength based on awardee’s capability to exceed requirements is sustained where the record shows that the evaluation finding was based on an erroneously inflated understanding of the awardee’s ability to exceed the government’s requirements.
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