SCOR2E-ATCS PLC and Guidehouse, Inc. v. Department of Homeland Security, FEMA (B-423315)

You should not care.

Category: Technical evaluation, price realism, best value tradeoff

Date: 15 May 2025

URL: https://www.gao.gov/products/b-423315

SCOR2E, a contractor team led by ATCS PLC and Guidehouse, protested FEMA’s award of a BPA to the Cadmus Group for technical assistance under an RFQ for management and consulting services. SCOR2E claimed FEMA unreasonably evaluated its technical quotation, wrongfully conducted a price realism analysis, and made a flawed best-value tradeoff. The protest was primarily based on alleged errors and unreasonable judgments in evaluating SCOR2E’s demonstrated prior experience and supposed application of unstated evaluation criteria. SCOR2E also criticized the documentation and weight given to the price premium and technical distinctions supporting Cadmus’s best-value selection.

Technical evaluation—no evidence of irrationality: SCOR2E argued that FEMA improperly downgraded its technical approach on four out of eleven experience topics. GAO reviewed each point and consistently found that FEMA’s evaluation was supported by the record: the agency reasonably concluded that SCOR2E’s examples did not demonstrate the breadth or type of experience FEMA sought. GAO emphasized that disagreement with evaluators’ subjective judgments is insufficient grounds for sustaining a protest.

No price realism analysis conducted: SCOR2E accused the agency of improper price realism, but GAO found FEMA only assessed price for reasonableness—consistent with the solicitation. The language cited by the protester reflected the awardee’s experience, not an improper positive view of a higher price.

Best-value tradeoff—well documented, reasoned: GAO rejected SCOR2E’s arguments that FEMA downplayed the price premium or failed to adequately explain its tradeoff reasoning. The record showed quantitative and qualitative consideration of all relevant factors.

Protest denied. GAO found no flaws or improper conduct in FEMA’s evaluation or award decision.

Digest

1. Protest that the agency unreasonably evaluated quotations is denied where the record shows the agency evaluated quotations in accordance with the terms of the solicitation.
2. Protest that the agency improperly conducted a price realism analysis is denied where the record shows that the agency did not conduct a price realism analysis.
3. Protest that the agency made a flawed best-value determination is denied where the record shows that its determination was reasonable.