IBS Government Services, Inc. (B-423583)

You should not care.

Category: Technical evaluation, past performance, AI brief

Date: 29 August 2025

URL: https://www.gao.gov/products/b-423583

IBS Government Services protested the Defense Intelligence Agency's award of a task order for financial audit support services to RMA Associates under a GSA Schedule solicitation, arguing the agency unreasonably evaluated its quotation under the technical and management approach factor. The protester primarily challenged the agency's finding that its quotation lacked an employee retention plan and disputed the evaluation of its past performance references.

Technical evaluation: GAO found that the solicitation explicitly required vendors to address employee retention as part of the staffing evaluation criteria. The RFQ stated that quotations would be evaluated based on "staffing, recruiting, employee retention, [and] personnel qualifications," making retention a stated requirement rather than an unstated criterion as the protester claimed. The record showed IBS's quotation did not address employee retention despite the clear solicitation requirement.

Past performance: The agency evaluated IBS as having submitted two relevant references, with one including experience with the acquire-to-require financial audit process. In comparing IBS to RMA, the source selection authority noted that while IBS had one reference involving A2R services performed as a subcontractor, RMA provided five references all including A2R services—four as prime contractor and one as subcontractor. The agency reasonably concluded this gave RMA a significant comparative advantage.

Citation misconduct: After the record closed, the intervenor requested dismissal, citing the protester's inclusion of citations to nonexistent GAO decisions in its pleadings. GAO noted this was similar to recent cases involving artificial intelligence-generated legal briefs with fabricated citations. While GAO denied the protest on its merits rather than dismissing it, the decision warned that future submissions with citations to nonexistent authority may result in sanctions.

The protest was denied.

Digest

Protest that the agency unreasonably evaluated the protester's quotation under the technical and management approach factor is denied where the record shows that the agency reasonably evaluated the protester's quotation in accordance with the terms of the solicitation.