OBX-MCR Alliance, LLC (B-422266.4)

You should not care.

Category: Price reasonableness, best value tradeoff, competitive prejudice

Date: 18 February 2025

URL: https://www.gao.gov/products/b-422266.4

OBX-MCR Alliance, LLC, a small business, protested GSA's award of a task order to Tecolote Research, Inc., for financial support services for the US Space Force under the OASIS Small Business Pool contract. OBX-MCR challenged GSA’s price reasonableness evaluation and best-value tradeoff, arguing that the agency improperly assessed Tecolote’s pricing and failed to justify the award decision:

• Price reasonableness: The agency used three price analysis methods—comparing proposed labor rates to incumbent bridge contracts, CALC+ historical data, and Bureau of Labor Statistics (BLS) rates. OBX-MCR claimed these methods were flawed. GAO found the agency’s approach reasonable.
• Best value tradeoff: OBX-MCR alleged GSA’s source selection decision lacked adequate documentation to justify Tecolote’s $51 million price premium. GAO ruled that while the agency’s redacted decision omitted some detail, it sufficiently supported the conclusion that Tecolote’s superior technical proposal justified the additional cost.
• Competitive prejudice: Even if OBX-MCR’s arguments had merit, GAO concluded it was not competitively harmed because the agency’s other price evaluation methods were sound, and OBX-MCR’s weaknesses posed serious performance risks.

Protest denied. GAO upheld the award, finding that GSA reasonably evaluated price reasonableness and conducted a proper tradeoff analysis, with Tecolote’s proposal demonstrating significantly higher technical merit and lower performance risk.

Digest

1. Protest that the agency’s determination of price reasonableness was unreasonable is denied where the agency reasonably compared the protester’s price to comparable historical pricing from various sources.
2. Protest that the agency’s best-value tradeoff was unreasonable and inadequately documented is denied where the redacted source selection decision produced by the agency in response to the protest sufficiently demonstrated that the agency reasonably concluded that the awardee’s higher-rated proposal was worth the associated price premium.