BTAS, Inc. (B-422624.2; B-422624.6)

You should not care.

Category: Cost realism, technical evaluation, reevaluation, OASIS

Date: 5 February 2025

URL: https://www.gao.gov/products/b-422624.2%2Cb-422624.6

BTAS, Inc., a small business in Beavercreek, Ohio, protested GSA) issuance of a task order to Credence Management Solutions, LLC, under the GSA OASIS small business IDIQ. The task order, supporting US Space Force’s Space Systems Command, required command staff support services. BTAS argued the agency’s cost realism and technical evaluations were unreasonable, specifically alleging GSA improperly failed to use the independent government cost estimate (IGCE) and the solicitation’s total evaluated price (TEP) range and failed to credit BTAS with additional technical strengths.

After an initial award to Credence, another offeror’s protest led GSA to take corrective action and reevaluate proposals. Upon reevaluation, BTAS and Credence both received overall "good" technical ratings, but Credence’s price was lower ($221.8M vs. $259.4M). The GSA found Credence’s quote represented the best value.

Cost realism evaluation and use of estimates: BTAS claimed GSA’s cost realism analysis was flawed, because it ignored the IGCE and the TEP range in the solicitation, resulting in competition’s not being conducted on a common basis. GAO found the solicitation did not require TEPs to be within the stated range to be realistic or reasonable. Agencies are permitted to use various analyses, including comparisons to competing offer sand Bureau of Labor Statistics data. GAO concluded GSA’s approach was reasonable and in line with procurement rules.

Technical evaluation consistency: BTAS contended its proposal should have received more strengths (and thus a higher rating) in the corrective action evaluation, because it had done so before. GAO reaffirmed that differing evaluation conclusions after corrective action are not itself evidence of impropriety and agencies are not required to justify differences absent a factual basis for protest.

The protest was denied in its entirety. This decision is a standard affirmation of agency discretion in evaluating price realism and technical proposals within the stated criteria and should reassure contracting officials, program managers, and counsel that the use of comparative cost analytics and evolving technical evaluations after corrective actions are acceptable absent clear evidence of irrational evaluation or deviation from specified criteria.

Digest

Protest that agency's cost realism evaluation improperly failed to consider the government estimate and the total evaluated price range stated in the solicitation is denied where agency reasonably relied on other comparisons to establish cost realism.

Protest challenging the agency's evaluation of the protester's technical proposal is denied where the evaluation was reasonable and consistent with the terms of the solicitation.