Innovative Management & Technology Approaches, Inc. (B-423190; B-423190.2)

You should not care.

Category: Technical evaluation, Cost or price evaluation, Past performance

Date: 3 March 2025

URL: https://www.gao.gov/products/b-423190

Innovative Management & Technology Approaches, Inc. (IMTAS), protested the FBI’s award of a call order to i3, LLC, under an RFQ for management of the agency’s enterprise mobile device products and data plans. IMTAS alleged the agency unreasonably evaluated quotations on price, technical approach, and past performance, arguing that the exclusion of its proposal for a minor pricing discrepancy was arbitrary and that its technical and past performance ratings were unreasonably low.

The FBI issued an RFQ under its ITSSS-2 BPA, requiring management of 40,000–50,000 mobile devices. IMTAS’s price proposal was excluded due to a $0.01 discrepancy in a labor rate compared to its BPA, even though the total price was correct; the agency declined to seek clarifications. IMTAS also received low confidence ratings on both technical and past performance factors, which outweighed its low price under the RFQ’s best value tradeoff structure. IMTAS challenged both its exclusion and the evaluations of both its own and i3’s proposals:

• Price evaluation and competitive prejudice: GAO found the agency erred in excluding IMTAS over the immaterial price discrepancy, but IMTAS was not competitively prejudiced because even with the correct price, its quote was rated so much lower on technical and past performance factors (which were more important) that it would not have had a substantial chance at award.
• Technical evaluation: IMTAS's argument that an equal number of strengths and weaknesses entitled it to a higher rating was rejected; GAO emphasized the qualitative nature of evaluation.
• Past performance: GAO found no evidence of disparate treatment; the FBI’s expectations about experience with SAFe methodologies were explicit in the RFQ, and IMTAS failed to sufficiently demonstrate experience at the required scale and complexity.
• All other challenges were found to be unsupported or abandoned.

The protest was denied. No actionable errors led to competitive prejudice, and the record confirms the agency acted within its evaluation discretion throughout.

Digest

Protest challenging the agency’s price evaluation of the protester’s quotation is denied where even though the agency unreasonably determined the protester’s pricing was incomplete the protester has not demonstrated it was competitively prejudiced by the agency’s actions.

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

Protest challenging the agency’s past performance evaluation of quotations is denied where the agency reasonably evaluated quotations against the stated evaluation criteria and in an even-handed manner.