GENCO Systems, Inc. (B-423304)
You should not care.
Category: Best value tradeoff
Date: 7 May 2025
URL: https://www.gao.gov/products/b-423304
GENCO Systems protested GSA’s issuance of a fixed-price task order under a Federal Supply Schedule BPA to Jay Shapiro & Associates for construction management services at the Addabbo Federal Building in New York. GENCO, the incumbent and lower-priced vendor, argued that GSA failed to perform a proper best value tradeoff and improperly relied on “unsupported deficiencies” in GENCO’s proposal to justify selecting a higher-priced competitor.
GAO denied the protest. The solicitation explicitly permitted a price-technical tradeoff and assigned price a 40 percent weight—GENCO received full price points but was found to have technical shortcomings, including failure to address off-hours coverage for weekends and holidays. Despite achieving near-identical total point scores (77.875 vs. 78), GSA’s contracting officer reviewed the substantive evaluation record and determined Jay Shapiro’s proposal offered superior value, particularly in staffing and project management planning.
GENCO’s central claim—that its lower price should have tipped the award in its favor given the nominal score difference—failed because the RFQ did not mandate price as a tie-breaker, and GAO reiterated that point scores are advisory, not dispositive. GAO also held that GENCO explicitly abandoned any challenge to the technical evaluation by disclaiming such intent in its comments.
Protest denied. Even in close-scoring evaluations, technical execution can justify a higher price under FAR Part 8 tradeoffs.
Digest
Protest that agency failed to properly consider protester’s price and unreasonably issued Federal Supply Schedule order to higher-priced vendor is denied where the record shows the agency’s source selection decision reasonably determined that successful vendor’s quotation provided the best value under the solicitation criteria.
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