Magellan Federal, Inc. (B-422803; B-422803.2)

Category: Technical evaluation, past performance

Date: November 13, 2024

URL: https://www.gao.gov/products/b-422803%2Cb-422803.2

You should not care.

Magellan Federal protested Army's award of a task order to Strategic Resources, Inc. (SRI), for master resilience training, alleging errors in key personnel evaluations, unequal treatment, and a flawed best-value determination. GAO dismissed or denied all claims.

Magellan argued SRI’s proposed key personnel statements were deficient and its personnel were unavailable, based on job postings and LinkedIn profiles. GAO found no evidence of deficiencies or that SRI knowingly misrepresented availability. Magellan also contended that SRI took exception to fixed-price terms, but GAO upheld the Army's determination that SRI's statements were standard equitable adjustment language and not exceptions. The protester further alleged the Army failed to credit Magellan’s proposal with deserved strengths or significant strengths, while treating SRI’s proposal more favorably. GAO concluded the evaluations were reasonable, emphasizing that the differences in scoring reflected real distinctions in the proposals, particularly regarding certifications.

Digest

1. Protest that the agency accepted a deficient key personnel statement of commitment from the awardee is denied where the record demonstrates that the statement of commitment complied with solicitation criteria.
2. Protest challenging the availability of key personnel based solely on job postings by the awardee is dismissed as failing to state a valid basis of protest. Protest that a key person is unavailable based on a change in employment prior to award is denied where the record shows that all proposed key personnel submitted statements of commitment, none of these statements were revoked, and the awardee did not otherwise have actual knowledge that any of its proposed key personnel had become unavailable.
3. Protest that the awardee’s proposal improperly took exception to the solicitation requirements is denied where the agency reasonably determined that the awardee’s assumptions were not exceptions to the requirements.
4. Protest challenging various aspects of the agency’s evaluation of the protester’s proposal and best-value determination is denied where the agency’s evaluation was reasonable and consistent with the terms of the solicitation.