[Protests of OPM Rejection of Proposals for Consulting and Training Services]

B-234141,B-234141.2,B-234141.4,B-234141.5: May 17, 1989

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Four firms protested the Office of Personnel Management's (OPM) rejection of their bids for management consulting and training services, contending that: (1) the technical proposal evaluation panel lacked key management representation; (2) the panel's written proposal assessments did not comply with internal OPM guidelines; (3) OPM did not allow adequate bid preparation time; and (4) OPM improperly evaluated the bids. GAO held that it would not review allegations regarding: (1) internal OPM bid assessment guidelines, since they did not have the force or effect of law; (2) the composition of the technical proposal evaluation panel, absent a showing of evaluator bad faith or bias; and (3) solicitation improprieties that the protesters untimely filed after bid opening. GAO also held that OPM reasonably excluded the protesters' bids from the competitive range, since: (1) technical scoring disparities among individual evaluators did not alone cast doubt on the evaluation's validity; and (2) bid deficiencies included limited organizational experience and limited understanding of the implementation strategy. Accordingly, the protests were denied.