A GAO decision released today, but dated November 15, 2006, reported that Advanced Federal Services Corp. protested the award of a contract to Eastek, Inc. under request for proposals (RFP) No. W9128Z-06-R-0001, issued by the Department of the Army Communications-Electronics Life Cycle Management Command for business administrative support services (BASS). The protester contended that the agency unreasonably evaluated offerors’ technical proposals and past performance and made an improper source selection decision. The protest was denied.
The GAO stated that in reviewing a procuring agency’s evaluation of an offeror’s technical proposal, “our Office’s role is limited to ensuring that the evaluation was reasonable and consistent with the terms of the solicitation and applicable statutes and regulations. As with any evaluation review, our chief concern is whether the record supports the agency’s conclusions To the extent a protester disagrees with an agency’s evaluation, such mere disagreement does not render an evaluation unreasonable; our Office will not question an agency’s evaluation judgments absent evidence that its judgments were unreasonable or contrary to the stated evaluation criteria.”
In other words, contractors who want to challenge the government’s evaluation of an offer submitted in response to a Request for Proposals (RFP) should understand that the GAO gives great latitude to federal agencies. The GAO will almost always yield to the discretion of the source selection official unless the protester can provide evidence that there was not a rational basis for the evaluation. See Advanced Federal Services Corp., B-298662, November 15, 2006.