All American Express Solutions, LLC (B-423530)

You should not care.

Category: Price realism, experience, past performance, resopnsibility

Date: 1 August 2025

URL: https://www.gao.gov/products/b-423530

All American Express Solutions, LLC, protested the VA’s award of a courier services contract to Rollin'O'Stop, LLC under RFQ No. 36C25725Q0351, set aside for SDVOSBs. The protest challenged the evaluation of the awardee’s allegedly "unreasonably low" price, Rollin'O'Stop’s purported lack of relevant experience, and the agency’s affirmative responsibility determination. The solicitation, issued under FAR Part 13, evaluated only technical approach and price on a best value basis, did not require past performance or experience as evaluation criteria, and had no provision for price realism analysis.

No requirement or authority for price realism evaluation on fixed-price procurement: All American’s claim regarding unreasonably low pricing amounted to a demand for a price realism analysis. GAO reiterated that price realism on fixed-price contracts may only be performed when specifically stated in the solicitation, which was not the case here.

No evaluation of experience or past performance: The protester asserted Rollin'O'Stop lacked experience, but the solicitation did not list either experience or past performance as evaluation criteria. An agency need not—and may not—evaluate factors not required by the RFQ. Complaints about the absence of such criteria must be raised preaward.

Affirmative responsibility determination challenges dismissed: GAO will review responsibility determinations only in rare cases, such as where significant integrity issues are raised. Poor or nonexistent past performance does not meet this standard, and the protest here contained no such allegations.

The protest was dismissed in its entirety.

Digest

Protest that agency unreasonably evaluated awardee's experience and low pricing is dismissed where the solicitation did not require the agency to conduct such an evaluation.