Tiber Creek Consulting, Inc. (B-422925; B-422925.2)

You should not care.

Category: Technical evaluation, process issue, cost or price evaluation

Date: 18 December 2024

URL: https://www.gao.gov/products/b-422925%2Cb-422925.2

Tiber Creek Consulting, Inc., protested the Army's award of a task order for managing the Army Training Requirements and Resources System (ATRRS) to Halvik Corporation. Tiber challenged the agency’s evaluation, alleging unreasonable weaknesses in its quote, disparate treatment, and an unjustified best value tradeoff in favor of the higher-rated, higher-priced offeror. GAO found the evaluation and tradeoff decision reasonable and supported by the record.

Evaluation of technical/management approach: Tiber’s proposed staffing plan for a key position (Senior Technical Manager-Web) was found insufficient due to reliance on a single individual for broad responsibilities, introducing performance risk. GAO upheld the weakness, noting Tiber's quote failed to clearly demonstrate how additional team members would meet requirements.

Disparate treatment claims: Tiber alleged similar features in its quote were evaluated less favorably than Halvik’s. GAO found no evidence of unfair evaluation or substantive equivalence in the competing approaches.

Best-value tradeoff decision: The Army determined Halvik’s superior technical approach and risk mitigation justified the $9 million price premium. GAO found the tradeoff decision well-documented and consistent with the solicitation.

The protest was denied as the agency’s evaluation and award decision were rational and consistent with the solicitation.

Digest

1. Protest of a weakness assessed under the most important aspect of the most important factor is denied where the agency’s rationale for the weakness is reasonable and consistent with the terms of the solicitation and the contents of the proposal.
2. Allegation of disparate treatment is denied where the protester fails to demonstrate that different evaluation results were based on substantively indistinguishable approaches.
3. Challenge of the best-value tradeoff as failing to support award to the higher-rated, higher-priced offeror is denied where the tradeoff decision is sufficiently documented and consistent with the terms of the solicitation.