[Protest of Army Rejection of Technical Proposal]

A small business protested the Army's rejection of its proposal under a request for technical proposals (RFTP). The protester contended that the rejection of its proposal was not rationally founded since it had supplied certain information in its proposal which the Army evaluators found lacking. It also contended that the Army's determination to reject its proposal was a nonresponsibility determination which should have been referred to the Small Business Administration (SBA) for consideration under the Certificate of Competency program. The RFTP stated that a proposal's technical approach would be rated as the most important factor and required that proposals demonstrate a comprehensive knowledge and understanding of the scope and degree of the technical efforts required. The RFTP cautioned offerers that any omission of information considered significant for the achievement of the technical requirements would be cause for considering the proposal unacceptable. In its evaluation of the protester's proposal, the Army found that it failed to meet the essential requirements of the RFTP and that the deficiencies could not be cured without major revisions. The Army's rejection listed 18 specific deficiencies including many involving the technical approach. The protester failed to directly challenge 15 of the alleged deficiencies with any detailed substantiation of its reasons for disagreement; rather, it contended that the Army erroneously found that the firm did not discuss 3 items. The protester concluded that GAO should find that its proposal was susceptible to being made acceptable. GAO will accept the considered technical judgment of a procuring agency as to the adequacy of a technical proposal, unless it is shown that the agency action was erroneous, arbitrary, or not made in good faith. In addition, an agency should not permit an offerer to remedy major proposal defects when such defects could only be cured through extensive revision. GAO stated that it is the responsibility of offerers to provide adequate information for the evaluation of their proposals under the established criteria. Accordingly, GAO found that the protester failed to show that the Army's determination was unreasonable. Since this protest involved technical acceptability, not responsibility, the Army had no obligation to refer the matter to SBA. Accordingly, the protest was denied.