The government is free to use a variety of evaluation factors in evaluating proposals. However the RFP must describe the factors and significant sub-factors to be used to evaluate proposals and their relative importance and agencies must evaluate the proposals according to the criteria established in the solicitation. A protest was sustained where the weight applied to evaluation factors in the source selection decision differed from that announced in the solicitation (Park Tower Management, v US, 67 Fed. Cl. 548).

The GAO addressed several protests where the agency’s source selection decision was irrational or inconsistent with the administrative record. The GAO sustained a protest where the source selection authority in making its cost/technical tradeoff decision had considered advantages in the protester’s proposal that would result in cost savings but did not consider other advantages that while not resulting in cost savings still furnished the government additional value (Coastal Maritime Stevedoring, B-296627). A protest was denied where the agency had reasonably determined that technical superiority was not worth the additional price where the GAO made the point that there was a "high burden" placed on protesters when they allege an agency’s best value determination was arbitrary and capricious (Brewbaker White Sands, B-295582).

FAR 15.304 requires agencies to consider cost or price in evaluating competitive proposals (R&G Food Service B-296435). The GAO found that price was not given meaningful consideration where the agency mechanically made award without conducting a tradeoff analysis which it ruled rendered price meaningless as an evaluation factor (The MIL Corp. B-294836). An agency’s upward adjustment to protester’s cost proposal following a cost realism analysis to reflect increased staffing was irrational since it conflicted with the agency’s technical evaluation that found the proposed staffing level a strength (Honeywell Technology Solutions, B-292354).

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