GAO sustained a protest that claimed that the agency’s best-value source selection decision was flawed, because the record lacked evidence of an adequate best-value tradeoff consideration.

The Defense Intelligence Agency (DIA or Agency) issued a task order RFP for the development and enhancement of enterprise applications. The RFP stated that the agency would evaluate technical management, program objectives, and price, in descending order of importance. After receiving seven proposals, DIA conducted discussions and accepted final proposals. The awardee received an overall technical/risk rating of acceptable, while Mantech’s proposal was rated outstanding. The Source Selection Authority (SSA) determined that although Mantech’s technical proposal was superior to the awardee’s, it was not worth the almost $75 million price premium, and awardee’s proposal clearly demonstrates that they can do the work.

Mantech protested the agency’s best-value tradeoff decision, arguing that the SSA improperly converted the best-value procurement into a lowest-price technically acceptable (LPTA) and that the agency failed to explain why Mantech’s superior technical approach did not merit the cost premium.

Although a best-value tradeoff does allow an agency to select a lower-price, lower-rated proposal, the agency must explain the trade-off rationale. GAO found that the record failed to provide an explanation for why the protester’s significantly higher technical proposal was not worth the price premium, especially when the RFP stated that technical considerations are significantly more important than price. The record also failed to provide a meaningful comparison among the proposals, instead of just reciting the ratings.

Takeaway: This is a classic case of an insufficient agency record resulting in a sustained protest. Disappointed offerors should ensure that the agency record contains sufficient explanation of best-value tradeoff decisions and may want to challenge bald assertions that their better technical proposal is not worth the extra cost.