Jacobs Engineering Group, Inc. (B-422853; B-422853.2; B-422853.3)
You should not care.
Category: Technical evaluation, past performance, IDIQ, downselect
Date: 26 November 2024
URL: https://www.gao.gov/products/b-422853%2Cb-422853.2%2Cb-422853.3
Jacobs Engineering Group, Inc. protested its non-selection for a Department of the Army procurement for architect-engineering (A-E) services supporting National Guard facilities across multiple states and territories. The Army had issued a solicitation under Brooks Act procedures, intending to award ten indefinite-delivery, indefinite-quantity (IDIQ) contracts with a combined ceiling of $225 million. Jacobs challenged the Army's evaluations of its proposal under several criteria and the selection of three competitors for contract negotiations.
The company argued that Army improperly evaluated its proposal under the least important criterion—geographic knowledge—by failing to prioritize subcriteria as required. Jacobs also contested its rating under professional qualifications, based on the evaluation of personnel resumes for eleven disciplines. Despite achieving "outstanding" in some key areas, Jacobs alleged Army failed to account for the priority ranking of disciplines, unfairly lowering its overall evaluation. Additional challenges targeted Army's assessment of past performance, including reliance on CPARS records containing marginal ratings.
GAO found that while Army made errors in evaluating Jacobs' geographic knowledge criterion, these errors were nonprejudicial. GAO also upheld the Army's evaluations of professional qualifications and past performance as reasonable, noting that Jacobs' disagreement with the ratings did not demonstrate errors. Ultimately, the protest was denied because Jacobs failed to establish that errors affected the Army's selection of the top-ranked firms, which had stronger evaluations in more critical areas.
Digest
- Protest challenging evaluation methodology under geographic knowledge criterion denied; agency’s error was non-prejudicial.
- Protest of professional qualifications criterion denied where overall assessment was consistent with solicitation priorities.
- Challenges to past performance ratings involving CPARS dismissed as unsupported.
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