Strategic Communications, LLC

DOCUMENT FOR PUBLIC RELEASE

The decision issued on the date below was subject to a GAO Protective Order. This redacted version has been approved for public release.

Decision

Matter of: Strategic Communications, LLC

File: B-423306.18

Date: May 12, 2026

John L. Holtz, Esq., Shane J. McCall, Esq., Nicole D. Pottroff, Esq., Gregory P. Weber, Esq., and Annie E. Birney, Esq., Koprince Mccall Pottroff LLC, for the protester.
Jennifer L. Howard, Esq., and Stephen T. O'Neal, Esq., National Aeronautics and Space Administration, for the agency.
Sarah T. Zaffina, Esq., and Heather Weiner, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Protest is denied where the agency reasonably eliminated protester's proposal from award consideration because the proposal failed to include required information.

DECISION

Strategic Communications, LLC (Strategic), of Louisville, Kentucky, protests the elimination of its proposal from the competition under request for proposals (RFP) No. 80TECH24R0001, issued by the National Aeronautics and Space Administration (NASA), for information technology (IT) products, cloud solutions, cybersecurity, and related services. The protester contends that the agency unreasonably eliminated its proposal from the competition for failing to provide required information.

We deny the protest.

BACKGROUND

NASA issued the solicitation on May 23, 2024, in accordance with Federal Acquisition Regulation part 15, seeking to award the sixth generation of the solutions for enterprise-wide procurement (SEWP VI) government-wide acquisition contract vehicle for IT products and services.[1] AR, Exh. 1A, RFP Cover Letter at 1. The solicitation will result in multiple government-wide indefinite‑delivery, indefinite‑quantity contracts under which fixed-price, time-and-materials, labor‑hour, fixed-price award fee, fixed-price incentive fee, and fixed-price economic price adjustment task orders can be issued. Id. The solicitation contemplated awarding contracts without discussions to all qualifying offerors for an ordering period of 10 years. Conformed RFP at  40, 117. The maximum ordering value is $20 billion. Id. at 44.

The solicitation advised that contracts will be awarded for three categories;[2] each category is self-contained with its own separate fulfillment requirements, quotation submission requirements, and evaluation criteria. Id. at 25-39. This protest concerns category B, ITC/AV service solutions. Protest at 2.

NASA is conducting this procurement in three phases. Conformed RFP at 117. As relevant to this protest, during phase 1, offerors were required to submit valid ISO 9001 and capability maturity model integration certifications, demonstrate that they met mandatory experience requirements, and submit a North American Industry Classification System code crosswalk. Id. at 117-19. For the mandatory experience requirement, the solicitation required offerors to submit four different relevant experience projects (REPs) addressing different technical areas related to the given category requirements. Id. at 105. Each project must be completed or ongoing within three years of the solicitation's release date and have a total value of at least $30 million for “a single specific contract, single award [indefinite-delivery, indefinite-quantity (IDIQ)] contract or blanket purchase agreement, or task order, but may not be based on a multiple[-]award IDIQ contract.” Id. Offerors must submit their projects using the REP template included with the solicitation. Id.; AR, Exh. 15B, Conformed RFP exh. 1, REP Template.

The solicitation notified offerors that that the agency would evaluate proposals on a pass/fail basis under phase 1 and that if a proposal did not meet all the requirements, the proposal would be ineligible for award and excluded from the competition. Conformed RFP at 118-19.

Strategic timely submitted its proposal, and as relevant here, identified in the REP template its four required experience projects. AR, Exh. 17A, Strategic Offer Vol. at 5. The agency reviewed Strategic's proposal and found one of the four projects submitted did not appear to meet the recency requirement--it was not ongoing or completed within three years of the soliciation's release date. COS at 5; AR, Exh. 19, Down‑Select Notice at 1. Specifically, Strategic's proposal identified an experience project for what the proposal described as a task order issued by the Defense Health Agency (DHA) for cloud services to be performed in the future between August 26, 2026, and June 22, 2028. AR, Exh. 17C, Strategic REP exh. 1, DHA at 1; see also COS at 5. Because the period of performance appeared to be a clerical error, the contracting officer looked up the contract in the federal procurement data system (FPDS-NG) to verify performance dates.[3] COS at 5; AR, Exh. 19, Down‑Select Notice at 1. Although the information in the system confirmed that the contract's period of performance dates were from September 30, 2022, through September 29, 2027, and therefore fell within the RFP recency requirement dates, the system listed the value of the contract as $5,049,947 and not $250,000,000 as set forth in Strategic's proposal. COS at 5; AR, Exh. 19, Down‑Select Notice at 1; see also Protest exh. 8, USASpending.gov, Delivery Order No. HT001522F0186. As a result, the agency concluded that the value of the DHA project submitted in Strategic's proposal was below the solicitation's $30 million requirement and NASA eliminated Strategic's proposal from the competition. COS at 5; AR, Exh. 19, Down‑Select Notice at 2.

On February 17, 2026, the agency notified Strategic that its proposal had been eliminated from the competition and provided Strategic with a written pre-award debriefing. AR, Exh. 19, Down‑Select Notice at 2. Strategic then requested that NASA reconsider the evaluation of its proposal and submitted additional information about the REP. The protester explained that the project submitted was in fact a DHA catalog and that the order number listed in the REP template was only for the first order placed under the catalog. AR, Exh. 18, Communications between NASA and Strategic at 1; AR, Exh. 20, Letter from Strategic to NASA dated Feb. 18, 2026, at 1, 4. NASA responded that it was “not accepting revised proposal information.” AR, Exh. 18, Communications between NASA and Strategic at 1. Thereafter, Strategic timely filed this protest with our Office.

DISCUSSION

Strategic argues that NASA unreasonably eliminated its proposal from the competition. According to Strategic, it included information in its proposal indicating that the disputed REPs concerned a DHA catalog valued at $250 million, which exceeded the solicitation requirement for an REP with a minimum value of $30 million. Protest at 6-8. Strategic asserts that the DHA catalog was equivalent to a single‑award blanket purchase agreement (BPA) that firms were permitted to use for their REP submissions. Id. at 7‑8. The protester contends that NASA improperly considered the single order valued at $5,049,947, instead of the catalog as a whole. See id. at 6‑8. As discussed below, we find no merit to this argument and deny the protest.

In reviewing a protest challenging an agency's evaluation, our Office will not reevaluate proposals or substitute our judgment for that of the agency, as the evaluation of proposals is a matter within the agency's discretion. See SDS Int'l, Inc., B-291183.4, B‑291183.5, Apr. 28, 2003, at 5‑6. Rather, we will review the record to determine whether the agency's evaluation was reasonable and consistent with the stated evaluation criteria and applicable procurement statutes and regulations. MVM, Inc., B‑407779, B‑407779.2, Feb. 21, 2013, at 6. In a negotiated procurement, a proposal that fails to conform to the material terms and conditions of the solicitation is considered unacceptable and may not form the basis for award. Wolverine Servs. LLC, B‑409906.3, B-409906.5, Oct. 14, 2014, at 3-4. An offeror bears the burden of submitting an adequately written proposal that contains all of the information required under a solicitation. Business Integra, Inc., B-407273.22, Feb. 27, 2014, at 3. Where a proposal omits, inadequately addresses, or fails to clearly convey required information, the offeror runs the risk of an adverse agency evaluation. Distributed Sols., Inc., B‑416394, Aug. 13, 2018, at 4. A protester's disagreement with the agency's judgment, without more, is insufficient to establish that an evaluation was unreasonable. MVM, Inc., supra at 5-6.

Here, the solicitation instructed offerors to submit four projects using the REP template provided with the RFP. Conformed RFP at 105. Each project was to be completed or ongoing within three years of the solicitation release date and have a minimum value of $30 million for a single contract or BPA. Id. Offerors were required to submit a narrative with the completed REP template that demonstrated the relevance of the work performed to the technical areas of the project example. Id. The solicitation also specifically notified offerors that proposals that did not meet all of the solicitation requirements would not be eligible for award and removed from the competition. Id. at 118‑19.

Strategic included a project for a DHA contract in its proposal. In this regard, Strategic's REP template provided the following information:

Contract Number: NNG15SC90B

Order Number: HT001522F0186

Project Title: Defense Health Agency

Customer: Defense Health Agency

Period of Performance: 08/26/2026 through 06/22/2028

Project Value: $250,000,000

AR, Exh. 17C, Strategic REP exh. 1, DHA at 1. In the REP narrative, the protester described this contract as a “task order for Cloud Services under the SEWP V contract” and explained the enterprise‑wide cloud services it provided to DHA in performance of the order. Id. at 2-3.

As noted above, the agency reviewed Strategic's proposal and found what was a clerical error regarding the period of performance of the DHA project. COS at 5; AR, Exh. 19, Down-Select Notice at 1. The agency then discovered that the value of the purported order was $5,049,947, not $250 million, as set forth in Strategic's proposal. COS at 5; AR, Exh. 19, Down-Select Notice at 1. The agency concluded therefore that the task order did not meet the $30 million minimum value as required by the RFP and eliminated Strategic's proposal from the competition because only three of the four required projects met the solicitation requirements. COS at 5; AR, Exh. 19, Down‑Select Notice at 2.

Only after its elimination from the competition did the protester provide NASA with additional information about the REP, explaining that it was not in fact a task order, but rather an agency catalog with a ceiling of $250 million. COS at 5; AR, Exh. 20, Letter from Strategic to NASA dated Feb. 18, 2026, at 1, 4. Strategic stated that “[i]n retrospect, perhaps Strategic should have referenced the [request for agency catalog] contract [number], in the order number field, instead of the first catalog order.” AR, Exh. 20, Letter from Strategic to NASA dated Feb. 18, 2026, at 1. Strategic explained that, in its view, the DHA catalog functioned as a single‑award contract or BPA and provided additional information about orders placed under the catalog. Id. at 2‑4.

Based upon our review of the record, we conclude that the agency reasonably evaluated the disputed REP. As noted above, the solicitation instructed offerors to submit four projects using the REP template provided with the RFP and specified that each project must have a minimum value of $30 million for a single contract or BPA. Conformed RFP at 105. The solicitation also specified that any proposal that did not meet all of the solicitation requirements would not be eligible for award and removed from the competition. Id. at 118‑19. Strategic submitted three REP projects that met the $30 million minimum requirement. AR, Exh. 17A, Strategic Offer Vol. at 5; AR, Exh. 19, Down-Select Notice at 1‑2. For its fourth REP, Strategic submitted a project that it identified as a task order in the proposal narrative. AR, Exh. 17C, Strategic REP exh. 1, DHA at 2. The agency confirmed the order had a value of less than $30 million based on public information. AR, Exh. 19, Down-Select Notice at 2. After the agency excluded Strategic's proposal from the competition, Strategic provided supplemental information to NASA explaining the order was from a catalog with a $250 million value. Exh. 20, Letter from Strategic to NASA dated Feb. 18, 2026, at 1, 4.

Strategic argues that NASA should have understood from the narrative section that the DHA project was a catalog with a value of $250 million, which in the protester's view, is analogous to a single‑award BPA, and therefore, permitted as a project under the solicitation. The protester, however, fails to show how its proposal, in fact, explained or demonstrated that the DHA project was a catalog with a value of $250 million. Rather, the record shows that NASA eliminated Strategic's proposal from the competition because the information in its proposal identified the REP as a task order, and the agency confirmed based on public information that the task order had a value of less than $30 million. The protester does not dispute that the order had a value of less than $30 million. Rather, the protester asserts that the agency should have understood from its proposal that the DHA project was a catalog, rather than a task order. The protester, however, points to nothing in the REP template or narrative of Strategic's proposal that indicated that the DHA project was a catalog. Indeed, the term “catalog” is not used anywhere in Strategic's proposal; instead, the proposal identifies the contract as a task order. See AR, Exh. 17C, Strategic REP exh. 1, DHA at 2. Moreover, the contracting officer was only able to verify that the value of the order number provided in the proposal (i.e., No. HT001522F0186) was $5,049,947. As discussed above, the record reflects that it was not until after Strategic's proposal was eliminated from the competition that the protester provided additional information to NASA explaining that the DHA project was an agency catalog. As referenced above, an offeror bears the burden of submitting an adequately written proposal that contains all of the information required under a solicitation. Business Integra, Inc., supra at 3. Here, Strategic failed to include information in its proposal sufficient to establish that it met the solicitation requirements. Without such information, we cannot conclude that it was unreasonable for the agency to find that the DHA project was a task order, rather than a catalog, and that the value of the task order failed to meet the $30 million value requirement. Accordingly, we find that the agency's evaluation was reasonable.

The protest is denied.

Edda Emmanuelli Perez
General Counsel