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Path: Consulting Services arrow Report & Digest arrow GCA Report Articles arrow GCA Report 2004 arrow Need Adequate Documentation to Justify Source Selection

Need Adequate Documentation to Justify Source Selection

(Editor’s Note.  The following illustrates the difference between a best value and lowest priced/technically acceptable procurement.)

The U.S. Marine Corps solicited a five month with three one-year options contract for lease and maintenance of washers and dryers where the solicitation contemplated award to be based on best value and where price was significantly more important than other factors – technical, management and past performance – combined.  The Request for Proposal was subject to FAR Subpart 12.6 that stated selection must be consistent with factors contained in the RFP and that any trade-offs considered must be fully documented for rationale of source selection.  USMC received quotes from five offerors and gave equal technical and management ratings to all; three vendors including Tiger received favorable ratings while B&E having no past performance ratings history received a neutral rating and since price was the most important factor, the Marines gave the contract to B&E.   Tiger protested asserting USMC “failed to perform an adequate price/technical tradeoff and did not follow the RFP’s evaluation plan and awarded the contract on a low priced, technically acceptable basis rather then on a best value basis.

The GAO ruled in the protester’s favor.  The USMC ‘s source selection rationale consisted of a one page “evaluation determination” and a matrix setting forth past performance ratings where all three vendors were rated “favorable” for past performance despite the fact the matrix showed Tiger’s references were “excellent” while the second ratings were “good” and the third only “marginal.”.  As for USMC’s source selection decision, the record only provided that “all evaluation factors were met by the proposals” and since price is the most important factor, B&E appears to be the successful bidder.  The GAO ruled (1) in the light of Tiger’s higher past performance ratings the record did not support the claim all three vendors were rated “favorable” and (2) the statements in the evaluation determination did not explain why B&E’s price advantage outweighed Tiger’s advantage under the past performance evaluation factor.  The GAO concluded it appeared that the award to B&E was made on the basis of low-priced, technically acceptable which abandoned the solicitation’s “best value” approach (Tiger Enterprises Inc., Comp. Gen. B-293951).

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