Advanced Management Strategies Group, Inc. (B-423290; B-423290.2)

You should not care.

Category: Staffing, MAS CTA

Date: 16 April 2025

URL: https://www.gao.gov/products/b-423290%2Cb-423290.2

Advanced Management Strategies Group, Inc. (AMSG), a service-disabled veteran-owned small business, protested DOE’s task order award to Harkcon, Inc., under an RFQ for administrative support services issued through the National Nuclear Security Administration’s (NNSA) TEPS III BPA. AMSG raised multiple challenges: that Harkcon’s quote included misrepresentations regarding key personnel availability (alleging a “bait and switch”), that Harkcon’s contractor teaming arrangement (CTA) violated procurement terms, and that DOE failed to perform a proper best value tradeoff. The GAO denied all protest grounds.

Key personnel misrepresentation (bait and switch) denied: GAO found no evidence that Harkcon knowingly proposed unavailable personnel or misled the agency. Recruitment efforts and internal job postings did not establish misrepresentation. The program manager was found reasonably available.

Alternate program manager not required preaward: The RFQ required designation of an alternate postaward, not in the quote. Harkcon’s language describing its PM as the “singular touch point” did not constitute an exception to solicitation terms.

CTA eligibility challenge denied: Although Harkcon was not the BPA holder, it was a valid CTA member under MELE Associates, which held the TEPS III BPA. The CTA held that its members may lead task orders, which would be executed under each participating CTA member’s contract.

Best-value tradeoff reasonable: GAO concluded the contracting officer appropriately considered both price and technical ratings, and documented why AMSG’s higher price was not justified by any added technical benefit. The protester’s disagreement with the tradeoff was insufficient.

Protest denied. The agency followed proper procedure, and no prejudicial error was found.

Digest

Protest challenging various aspects of the agency’s evaluation of vendors’ quotations is denied where the protester has not demonstrated that the evaluation was unreasonable or inconsistent with the terms of the solicitation.

Protest that the agency failed to perform a meaningful best-value tradeoff is denied where the record shows that the agency’s tradeoff decision was reasonable and adequately documented.