Professional Analysis, Inc. (B-422226.4; B-422226.5)

Category: Price evaluation, technical evaluation

Date: November 4, 2024

URL: https://www.gao.gov/assets/880/873182.pdf

You should not care.

Professional Analysis, Inc. (PAI), protested Navy's award of a logistics services contract to CACI, Inc. Federal, challenging the evaluation of CACI's proposal. PAI alleged that CACI’s price was unrealistically low and failed to meet technical requirements, and CACI took exception to solicitation terms. GAO dismissed parts of the protest as untimely and denied the remaining arguments, finding Navy’s evaluation reasonable and consistent with the solicitation’s terms.

Key issues included whether CACI’s assumptions constituted an exception to solicitation requirements and whether a price realism analysis was mandatory. GAO concluded that the solicitation only required a price reasonableness evaluation, not realism. GAO also upheld the agency's rejection of claims about disparate treatment, noting consistent evaluation of both proposals.

Dismissed in part and denied in part. GAO ruled that PAI’s claims either lacked merit or were untimely, emphasizing adherence to procedural timeliness requirements and validating the agency's methodology.

Digest

Protest allegations are dismissed where the protester withdrew and abandoned its initial arguments and instead raised new untimely arguments. 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, and where proposal language in question reflects the reservation of a right to request, rather than receive, a price adjustment.