Horizons Youth Services (B-423202)

You should not care.

Category: Proposal compliance, fonts, latent ambiguity

Date: 7 March 2025

URL: https://www.gao.gov/products/b-423202

Horizons Youth Services protested its exclusion from competition under a Department of Labor RFP for operation and management services at the Cascades Job Corps Center. The firm was disqualified for failing to comply with the RFP’s font type and page limitation requirements. Horizons argued that Arial Narrow was an acceptable variation of Arial, that the agency’s interpretation created a latent ambiguity, and that the deviation should have been waived as a minor informality.

The RFP explicitly required proposals to use Times New Roman, Arial, Garamond, or Calibri in twelve-point font. Horizons submitted its proposal in Arial Narrow, which is a more condensed version of Arial, allowing it to fit additional content within the page limits. GAO upheld DOL’s decision that using Arial Narrow gave Horizons an unfair advantage by effectively increasing the allowable page count beyond the competition’s limit.

GAO found the solicitation’s font requirements to be unambiguous and ruled that Horizons' failure to comply justified its exclusion from the competition. It rejected the protester’s argument that the agency should have reformatted its proposal or considered alternative interpretations of “Arial.”

While agencies may waive minor informalities, GAO agreed with DOL that Horizons’ noncompliance was material and could not be overlooked. Protest denied.

Digest

Protest challenging protester’s elimination from the competition is denied where the agency reasonably determined that its technical proposal failed to comply with the solicitation’s font type and page limitation requirements thereby giving the protester an unfair competitive advantage.