[Protest of Geographic Limitations in GSA RFP for Operation of Government Credit Card Program]

A firm protested that a General Services Administration (GSA) request for proposals (RFP) for the operation and maintenance of the U.S. Government National Credit Card Program unduly restricted competition, contending that: (1) the geographic restriction unreasonably precluded it from competing even though it had previously provided the services; (2) the RFP was issued on a sole-source basis to the incumbent contractor; and (3) a delay in the contract commencement date favored the incumbent contractor. Although the protester submitted an unsolicited offer, GSA awarded the contract to another firm because it determined that the services were urgently needed. GAO found that: (1) GSA failed to show that the scope of its geographic restriction reasonably reflected the agency's needs; (2) administrative convenience did not provide a basis for imposing a restriction which led to a sole-source award; (3) additional travel costs did not justify the geographic limitation; and (4) because the geographic restriction unduly limited competition, GAO did not need to consider an allegation that GSA delayed issuing the solicitation. Because of the urgent need for the contract award, GAO did not recommend contract termination and resolicitation; however, it recommended that contract options not be awarded at the end of the basic term and a new competition be conducted at that time which did not contain a geographic restriction. The protester also requested reimbursement of the costs of pursuing its protest and preparing its proposal. Since GSA unreasonably excluded the protester from the procurement, GAO allowed the costs of pursuing the protest; however, GAO found that the protester was not entitled to recover its proposal preparation costs since its offer was not solicited and it was clear that GSA would not consider the proposal. Accordingly, the protest was sustained, the claim for protest preparation costs was allowed, and the claim for bid preparation costs was denied.