BrightPoint, LLC (B-423392; B-423392.2; B-423392.3)

You should care.

Category: Technical evaluation, experience, best value tradeoff

Date: 25 June 2025

URL: https://www.gao.gov/products/b-423392%2Cb-423392.2%2Cb-423392.3

BrightPoint, LLC, a small disadvantaged business, protested USDA’s issuance of a task order to MetaPhase Consulting, LLC, under RFQ No. 12314425Q0031 for IT services supporting USDA’s Integrated Acquisition System (IAS), via the GSA STARS III GWAC. BrightPoint alleged USDA unreasonably evaluated MetaPhase’s prior experience and conducted an unequal, unreasonable best value tradeoff.

GAO dismissed BrightPoint’s speculative arguments that only it could offer equivalent technical capability, finding these lacked any factual support. Arguments about weaknesses assessed to its own quote were deemed abandoned due to minimal response to the agency's explanations. GAO also denied arguments that MetaPhase’s prior experience should have been rated lower due to project value or duration differences, as the solicitation did not specify size or value thresholds nor require experience in each desired element.

GAO sustained the protest of USDA's best value tradeoff and SSEB evaluation. USDA failed to meaningfully respond to BrightPoint’s plausible allegations of unequal treatment, particularly where both offerors appeared to have demonstrated similar experience. GAO found USDA’s records failed to link SSEB findings to RFP requirements and did not explain why feature-equal quotations were assessed differently, thus casting doubt on whether quotations were evaluated fairly.

The protest was sustained in part (on best value/tradeoff grounds), denied in part (prior experience challenge), and dismissed in part (speculative or abandoned issues). Best value tradeoff decisions must be supported by a clear evaluation rationale and consistent with the solicitation; speculative or conclusory protest grounds will be dismissed, but agencies ignore allegations of disparate evaluation at their peril.

Digest

Protest alleging various errors in agency’s evaluation of awardee’s quotation under solicitation’s non-price factors are dismissed where the protester’s claims are speculative and fail to state a valid basis of protest.Protest challenging the agency’s evaluation of the awardee’s prior experience is denied where the agency’s evaluation was reasonable and consistent with the terms of the solicitation.Protest challenge to the source selection evaluation board findings and subsequent best-value tradeoff analysis is sustained where the protester raises various colorable allegations that the agency’s selection decision was inconsistent with the solicitation’s evaluation criteria and did not give equal consideration to the protester’s and awardee’s quotations, and the agency did not meaningfully respond to the allegations.