Chaedrol GAO Protest Log 20240927: Guidehouse Inc. (B-421227.2, B-421227.3)

You should not care, but read for discussion of a case where evaluation was not in line with solicitation.

Category: Evaluation

Date: August 26, 2024

URL: https://www.gao.gov/products/b-421227.2%2Cb-421227.3

In this case, Guidehouse Inc. Virginia, protested the award of a contract to KPMG LLP by the Office of the Director of National Intelligence (ODNI) under solicitation No. 2021-20111300002S for advisory services related to the National Intelligence Program. Guidehouse contended that the agency improperly evaluated the proposals and made an unreasonable best-value tradeoff decision, claiming that KPMG’s technical proposal did not meet the solicitation's requirements.

First, Guidehouse argued that the agency failed to adequately penalize KPMG for not meeting material solicitation requirements, particularly concerning the qualifications of proposed personnel. GAO noted that an agency must evaluate proposals based on the stated criteria and found that KPMG's proposal was inadequately documented in some areas. Additionally, Guidehouse contested the evaluation of its management proposals, specifically claiming that the agency assigned unreasonable weaknesses to its program manager's qualifications.

GAO's analysis underscored the principle that an agency's evaluation must align with the solicitation's stated criteria. They determined that the agency's failure to document its evaluation of KPMG's compliance with required labor qualifications warranted sustaining the protest.

Digest

1. Protest alleging that the agency unreasonably evaluated the awardee’s technical proposal is sustained where the record does not reflect that the agency evaluated a required staffing submission consistent with the solicitation.

2. Protests challenging the agency’s evaluation of strengths in the protester’s technical and management proposals are denied where the record reflects the evaluation was reasonable and consistent with the solicitation’s evaluation criteria.

3. Protest that the agency unreasonably concluded that the protester’s proposed program manager did not meet the requirements for the position is sustained where the stated basis for the agency’s conclusion is inconsistent with the solicitation and the protester’s proposal.