22nd Century Technologies, Inc. (B-422659.5; B-422659.6)

You should not care; however, detailed documentation was critical in protest defense.

Category: Cost or price evaluation, best value tradeoff
Date: 14 January 2025
URL: https://www.gao.gov/products/b-422659.5%2Cb-422659.6

22nd Century Technologies, Inc. (22nd Century), protested the issuance of a call order to Lamb Informatics Limited by the Administrative Office of the US Courts (AOUSC) for centralized IT management and operational support services. 22nd Century alleged that AOUSC improperly focused on price, failing to compare the relative merits of proposals, effectively converting the award basis from best value to lowest price technically acceptable (LPTA).

The procurement used a tradeoff process emphasizing technical approach and corporate experience as more important than price, although price importance increased with technical parity. 22nd Century and Lamb Informatics received identical high confidence ratings across nonprice factors. AOUSC awarded the contract to Lamb Informatics, noting a slight technical edge and a $199,352 lower price.

GAO determined the agency’s documentation was sufficient to establish awareness of the relative merits and costs of competing proposals. AOUSC’s justification emphasized price parity and Lamb’s marginally stronger technical approach.

GAO denied the protest, upholding the reasonableness of the agency’s tradeoff decision.

Digest

Protest challenging agency’s best-value determination and subsequent source selection decision is denied where the record demonstrates the agency’s conclusions were reasonable and adequately documented.