Resource Management Systems, Inc. (B-422779.2)

You should not care.

Category: Compliance, price evaluation

Date: 10 February 2025

URL: https://www.gao.gov/products/b-422779.2

Resource Management Systems, Inc. (RMS), a small business based in Morris, Georgia, protested VA’s rejection of its proposal under RFP No. 36C24724R0057 for ambulance and stretcher van services to the Carl Vinson VA Medical Center. RMS argued that its disqualification—based on its use of outdated estimated quantities in the price schedule—was improper and that the agency should have sought clarification before rejecting the bid. RMS claimed the mistake was immaterial and clerical in nature.

GAO emphasized that the amendment to the RFP clearly required offerors to use a revised price schedule and warned that failure to do so would result in rejection. RMS failed to apply the revised schedule across all CLINs, resulting in a pricing discrepancy of more than $680,000—a change GAO found material. GAO reiterated that it is the offeror’s responsibility to submit a compliant proposal.

The decision reinforced that under FAR 15.306, agencies may—but are not required to—engage in clarifications, and that such exchanges cannot be used to cure material omissions. GAO cited previous decisions to support its finding that the agency acted within its discretion in rejecting RMS’s proposal without further engagement.

The protest was denied.

Digest

Protest challenging the agency’s rejection of the protester’s proposal for failing to utilize an amended price schedule is denied where the record demonstrates that the agency’s evaluation was reasonable and in accordance with the terms of the solicitation; it is an offeror’s responsibility to submit an adequately written proposal, and agencies are generally not required to engage in clarifications that could give offerors an opportunity to clarify aspects of their proposals.