Is Alliant 2 now bulletproof?

In my post yesterday about the Alliant 2 pre-award protest decision, I closed with the line that when final awards are made, we’ll like see another batch of protests.

But I’m having second thoughts about that conclusion. If you read the Government Accountability Office decision that was published yesterday, there’s just not a whole lot left to protest.

The decision affirms the General Services Administration evaluation criteria and general approach to the contract.

The four protesters – Sevantec, InfoReliance Corp., Enterprise Information Services Inc. and Buchanan & Edwards – raised several questions about the evaluation criteria, particularly about this concept of “highest technically rated with a fair and reasonable price.”

The Federal Acquisition Regulation doesn’t talk about that kind of approach; it only talks about LPTA and best value trade-off evaluations. But the regulations recognize that these aren’t the only two processes for source selection; therefore, GAO rejected that argument and affirmed GSA’s evaluation approach.

So there isn’t much wiggle room to protest on that point post award.

The protesters also went after the self-scoring system that GSA is using for proposals. Bidders assign themselves points for relevant experience, past performance, systems, certifications and clearances, and organizational risk assessment. The solicitation provided for a total of 83,100 points. Bidders also have to provide documents to support their scores.

There is nothing in the decision that knocks a hole in this approach.

Objections were raised on how small businesses received points for their past experience. Again, GAO said this was reasonable.

The decision shouldn’t be a surprise because GSA went through some very similar objections and protests when it was awarding OASIS.

That was the pioneer for using a self-scoring process for the proposals. OASIS faced many pre-award protests but only one protest after awards were made.

In that case, VSE Corp. argued that GSA unreasonably evaluated its experience. GAO denied the protest. 

For Alliant 2, GSA says it is going to make about 60 awards, and the protesters went after this saying 60 isn’t enough to assure enough competition at the task order level. They cited Alliant 1, where half of the task orders only had one bidder.

But GSA has added what it calls participation requirements, such as making primes bid on a minimum number of task orders each year.

GAO shut the door on this objection, as well.

The evaluation criteria is the most common grounds for protests and GAO has affirmed the approach.

Because the proposals are self-scoring, it is going to be hard for companies that don’t make the cut to 60 argue that they should be added.

There are still some cracks of light for a protest such as what VSE argued, but they were unsuccessful.

So, GSA may have cleared the decks of the risks of protests going forward, or at least any protest that could seriously derail the contract.