[Protest of GSA Exclusion of Proposal From Competitive Range]
Highlights
A firm protested the General Services Administration's (GSA) exclusion of its proposal for travel management centers from the competitive range, contending that GSA: (1) unreasonably excluded its proposal from the competitive range; (2) improperly downgraded its technical proposal; and (3) was biased in the awardee's favor due to a conflict of interest. GAO held that: (1) it would not consider a competitive range determination absent a showing that the determination was unreasonable or arbitrary; (2) GSA properly downgraded the protester's technical proposal for failure to discuss accreditation; (3) the protester was not sufficiently interested to challenge the GSA determination to include the awardee in the competitive range; and (4) the protester untimely protested alleged solicitation improprieties. Accordingly, the protest was denied in part and dismissed in part.