Paragon Systems, Inc. (B-422828; B-422828.2)

You should not care.

Category: Staffing plan, standing

Date: 19 November 2024

URL: https://www.gao.gov/products/b-422828%2Cb-422828.2

Paragon Systems, Inc., protested the US Capitol Police's award of a BPA for unarmed security guard services, challenging its technical evaluation and the agency’s best-value tradeoff. Paragon claimed that the agency unreasonably rated its proposal as "unacceptable" for failing to clearly demonstrate a staffing plan to cover 77 security posts, alleging that the evaluation applied unstated criteria.

GAO found the agency reasonably assigned a deficiency to Paragon’s quotation because it failed to articulate how it would meet full staffing requirements. The agency relied on the RFQ's explicit requirement for vendors to demonstrate sufficient staffing and failed to infer details not provided. Due to the "unacceptable" rating, Paragon was deemed ineligible for award, and its additional protest arguments were dismissed for lack of standing.

GAO affirmed that the agency’s evaluation adhered to solicitation criteria and that the protester's conclusory statements about staffing did not meet the requirement for a clear, actionable plan. The protest denied in part and dismissed in part.

Digest

1. Protest challenging agency’s evaluation of quotation as unacceptable is denied where the evaluation was reasonable and consistent with the terms of the solicitation.
2. Protester is not an interested party to challenge other aspects of agency’s evaluation where the protester was not eligible for award as a result of submitting a technically unacceptable quotation.