Parsons Government Services Inc. (B-422849)

Parsons Government Services Inc. (B-422849)

Category: Technical evaluation, past performance, process issue

Date: 21 November 2024

URL: https://www.gao.gov/products/b-422849

You should not care.

Parsons Government Services protested GSA’s award of a task order to ManTech Advanced Systems International for intelligence and cyber operations solutions. Parsons alleged flaws in the evaluation of technical and management approaches, key personnel, and ManTech’s alleged unfair competitive advantage from hiring a former government official. Key issues:

1. Evaluation flaws: GAO found GSA's evaluation reasonable and consistent with the solicitation's terms. For example, Parsons received weaknesses for focusing OCO support on a single entity (CNMF) without demonstrating broader applicability to other mission partners.
2. Unfair competitive advantage: Parsons argued ManTech gained an advantage from employing a former Navy cyber official. GAO denied this claim, as evidence showed the official lacked access to proprietary data and did not influence the proposal process.
3. Best value decision: GAO upheld GSA’s determination that ManTech’s technical superiority outweighed Parsons’ lower cost.

GAO concluded the agency's evaluation and award decision were reasonable, and Parsons did not substantiate its claims of unfair competitive advantage. This protest is a reminder that agencies retain discretion in technical evaluations, and protests relying on speculation or disagreement with evaluation outcomes are unlikely to succeed.

Digest

1. Protest challenging evaluation of proposals is denied where the record demonstrates that the evaluation was reasonable, consistent with the solicitation, and did not result from unequal treatment of proposals.
2. Protest alleging that awardee gained an unfair competitive advantage based on employment of a former government official is denied where the record shows that the individual did not have access to non-public, competitively useful information and was not involved in the drafting of the solicitation or the awardee’s proposal.