Reston Consulting Group, Inc.

Decision

Matter of: Reston Consulting Group, Inc.

File: B-423493; B-423493.2; B-423493.3

Date: August 1, 2025

DIGEST

Protest challenging agency’s evaluation of quotations and best-value tradeoff decision is denied where the record reflects that the evaluation and decision were reasonable, consistent with the terms of the solicitation, and adequately documented.

Reston Consulting Group, Inc., a small business of Herndon, Virginia, protests the issuance of a task order to IgniteAction, LLC, a small business of Coral Springs, Florida, by the Department of the Treasury, Internal Revenue Service pursuant to request for quotations (RFQ) No. 25PR-SSPDIR-0117 under the Infrastructure Operations Support Services (IOSS) blanket purchase agreement (BPA) for information technology (IT) services. The protester alleges that the agency erred in the conduct of its evaluation of quotations and best-value tradeoff.

We deny the protest.

BACKGROUND

On February 18, 2025, the agency issued the RFQ pursuant to the procedures of Federal Acquisition Regulation (FAR) subpart 8.4 to all holders of the IOSS BPA seeking to issue a single task order on a fixed price basis for IT support services. Memorandum of Law (MOL) at 2. The RFQ contemplated making award based on a best-value tradeoff between three factors, which are listed in descending order of importance: (1) management approach; (2) transition plan; and (3) price. Agency Report (AR), Tab F.3, RFQ at 90. Of note, the RFQ explained that, notwithstanding that the technical factors were more important than price, the agency reserved the right to make award to a lower technically rated, lower-priced vendor rather than to a higher technically rated, higher-priced vendor, and that “the closer the technical ratings of the various quotes are to one another, the more important price consideration becomes in determining the best value.” Id. at 93.

Relevant to this protest, the RFQ required vendors to propose both key personnel and a staffing plan to meet the requirements for five specific task areas.[1] Id. at 2-3. Additionally, the RFQ provided an estimated level of effort (LOE) for staffing and explained that the estimated LOE would be used to evaluate quotations, but that vendors could propose a different LOE. Id. at 4. Moreover, while vendors were permitted to deviate from the provided LOE, the agency cautioned in answers to vendor questions that each of the five task areas should have, at minimum, one senior position or key person as project lead, and that vendors must propose a labor category mix that best meets the complexity and skill levels required to meet the requirements. AR, Tab F.2, Vendor Questions and Answers, Question 37. Additionally, the RFQ required staffing plans to reflect an adequate resource headcount and ability to promote successful and timely contract performance. RFQ at 91.

With respect to transition plans, the RFQ instructed vendors to address their approach to ensuring a smooth transition, and describe how they would staff, train, measure and manage the effort at the time of award to maintain, or increase, the existing level of productivity that currently exists. RFQ at 91. Vendors were also required to provide a timeline after award to pick up and continue the effort to include personnel and necessary credentials required to continue without disruption of service. Id.

Concerning price, the RFQ explained that the agency would evaluate proposed prices to determine if they were fair and reasonable, reflected a clear understanding of the requirements, and were consistent with the vendor’s quote. Id. at 93. Additionally, the RFQ explained that the price evaluation “may” also include an evaluation of price for the purpose of assessing the risk inherent in a vendor’s approach, and that quotations that are unrealistic from a technical or price perspective may be reflective of an inherent risk, lack of competence, or a failure to comprehend the complexity and risks associated with the RFQ. Id. However, in response to a vendor question concerning whether the agency intended to evaluate price realism, the agency answered “No.” AR, Tab F.2, Vendor Questions and Answers, Question 8.

On February 27, the agency received quotations from all four holders of the IOSS BPA, including the protester and awardee. MOL at 3. All four quotations received the highest adjectival ratings for the non-price factors--that is, all quotations received a rating of “High Confidence” for both non-price factors. Contracting Officer’s Statement at 6. IgniteAction, however, submitted the lowest priced quotation with an evaluated price of $37,374,432. Id. By contrast, Reston’s evaluated price was $43,545,134. Id. The agency ultimately concluded that IgniteAction’s quotation represented the best value because it was significantly cheaper than other quotations, and the technical advantages of the other quotations did not merit paying “millions of dollars as a price premium.” AR, Tab G.4, Best-Value Determination Memorandum at 6. This protest followed.

DISCUSSION

The protester challenges the agency’s evaluation of quotations and best-value tradeoff in several respects. First, the protester alleges that the agency erred by failing to recognize numerous advantageous features of its quotation as warranting the assignment of additional strengths or significant strengths.[2] Protest at 11-22. Second, the protester alleges that the agency erred in evaluating the awardee’s management approach, which the protester argues did not adequately address the solicitation’s requirements and was inconsistent with the awardee’s price volume. Protest at 22-25; 2nd Supp. Protest at 3-6. Finally, the protester contends that the agency erred in the conduct of its best-value tradeoff by improperly treating substantively different quotations as technically equal and impermissibly making award on a lowest-price technically acceptable (LPTA) basis. For the reasons that follow, we find no basis on which to sustain the protest. We address these arguments in turn.[3]

Unacknowledged strengths

The protester alleges that the agency erred in evaluating its quotation by failing to recognize several aspects of the quotation as warranting the assignment of additional strengths or significant strengths. Protest at 11-22. For example, the protester alleges that its quotation should have received a significant strength because it explained its key personnel’s experience supporting the agency, noted that they were exclusively committed to remaining with the protester, and identified an additional, fifth key person beyond the four key personnel required by the RFQ. Id. As an additional example, the protester contends that, as the incumbent, it was the only vendor who could propose a zero or one-day transition period and presented the lowest transition risk to the agency, and it should have received a significant strength for that feature of its quotation. Id.

In response, the agency contends that, in general, the protester’s quotation was already very highly rated, and the agency contemporaneously recognized the protester’s retention of personnel and reduced risk of disruption of services as positive features of its quotation. MOL at 24-25. Moreover, the agency noted that it did not view exclusive commitments or the proposed additional key person to be meaningfully advantageous to the agency. Id. Similarly, while the evaluators acknowledged that the protester proposed a shorter transition period than other vendors and that this reduced the risk posed by the protester’s quotation, they acknowledged this benefit, but did not view this advantage as a significant benefit to the agency. Id.

In reviewing an agency’s technical evaluation of vendor submissions under an RFQ, we will not reevaluate the quotations; we will only consider whether the agency’s evaluation was reasonable and in accord with the evaluation criteria listed in the solicitation and applicable procurement statutes and regulations. HP Enterprise Servs., LLC, B‑411205, B-411205.2, June 16, 2015, 2015 CPD ¶ 202 at 5. A protester’s disagreement with the agency’s judgment, without more, does not establish that an evaluation was unreasonable. DEI Consulting, B-401258, July 13, 2009, 2009 CPD ¶ 151 at 2. This is particularly true where a protester simply disagrees with the agency’s assessment of the weight or significance of features of proposals or quotations. See Protection Strategies, Inc., B-416635, Nov. 1, 2018, 2019 CPD ¶ 33 at 8 (explaining that technical evaluators have considerable discretion in determining whether a proposal “deserves a ‘good’ as opposed to ‘very good’ rating”) (quotation omitted). Moreover, an agency is not required to contemporaneously document all “determinations of adequacy” or explain why a quotation did not receive a strength, weakness, or deficiency for a particular item. Allied Tech. Group, Inc., B‑412434, B-412434.2, Feb. 10, 2016, 2016 CPD ¶ 74 at 13.

Here we see no basis to question the agency’s conclusion that the protester’s quotation did not merit additional strengths on these bases. For example, the contemporaneous record reflects that the agency reasonably considered that the protester’s ability to retain staff was an advantage of the protester’s quotation. See AR, Tab G.4, Best- Value Determination Memorandum at 7-8. To the extent the protester argues that this aspect of its quotation should have been more heavily weighted, its disagreement with the agency’s judgment provides no basis on which to sustain the protest. Protection Strategies, Inc., supra.

While the protester is correct that the contemporaneous record does not reflect specific consideration of the protester’s additional fifth key person, agencies are not required to contemporaneously document why a specific quotation or proposal feature did not receive a strength. Allied Tech. Group, Inc., supra. As the agency explains in response to the protest, a key personnel requirement in a solicitation, among other things, provides an agency with additional information about the qualifications of personnel who will work in positions that the agency has identified as significant to the performance of the requirements. It is not clear in what way the protester’s identification of an additional person is, in fact, advantageous to the agency where the agency did not consider that position to be significant to the performance of the effort. In short, the record reflects reasonable consideration of this aspect of the protester’s quotation, and the protester simply disagrees with the agency’s technical judgment.

Concerning the transition plan, the contemporaneous record likewise reflects that the technical evaluators were aware of and considered the features the protester claims were not appropriately considered. Specifically, the technical evaluators noted that the protester’s quotation likely presented “a lower risk of service degradation during the initial few months of the contract,” and the protester’s transition plan posed “minimal risk” to operations. AR, Tab G.1., Consensus Technical Evaluation Report at 2. However, while the evaluators documented their consideration of these benefits of the protester’s quotation and assigned the protester the highest adjectival rating for the transition plan factor, they did not identify this feature as meriting additional recognition. Id. This is unobjectionable. See, e.g., Tuknik Gov’t Servs., LLC, B-422862.2, Dec. 30, 2024, 2025 CPD ¶ 17 at 4 (“[T]here is no requirement that an incumbent be given extra credit for its status as an incumbent, or that an agency assign or reserve the highest rating for the incumbent contractor.”). Where, as here, the agency reasonably considered and positively credited an aspect of the protester’s quotation, we see no basis to disturb the judgment of the agency that this quotation feature did not warrant more significance.

Awardee’s Management Approach and Price Quotation

Concerning the awardee’s quotation, the protester advances two principal arguments. First, the protester contends that the awardee deviated from the agency’s estimated LOE without adequately explaining how it would accomplish the necessary work. Specifically, the protester notes the awardee proposed only [DELETED] full-time-equivalents (FTEs) for task 1, where the agency estimated that three FTEs would be required to accomplish that task. Comments and Supp. Protest at 7-9, 15-17. Second, the protester argues that the awardee’s narrative in its management approach is internally inconsistent and discusses numerous staff positions that are not included in the awardee’s price quotation. 2nd Supp. Protest at 3-6. As a result, the protester contends that the awardee’s management approach was fatally inconsistent both with itself and with the awardee’s price quotation, which poses significant risk that IgniteAction will either not be able to perform the work as described in its quotation or will later seek an equitable adjustment for these additional unpriced positions. Id.

In response to the protester’s first argument, the agency explains that the solicitation did not require vendors to adhere to the agency’s estimated LOE, but rather simply noted that the agency would use that estimate in evaluating quotations. Supp. MOL at 10-12, 16-19. More significantly, the agency notes that, while the protester is correct that the awardee proposed [DELETED] fewer FTE for task 1, that was because the awardee proposed [DELETED] additional FTE for task 3, in effect shifting staff between tasks as a result of its unique technical approach. Id. As a result of these and other shifts, the total FTEs quoted by the awardee were almost exactly the same as the agency’s total estimated LOE, with the only total reduction in staffing being a half FTE reduction in LOE for a junior position in the later option years. Id. As a result, the agency concluded that the awardee’s staffing did not pose meaningful risk in this respect. Id. Additionally, the agency notes that the protester similarly proposed to move FTEs between task areas, and, as a result, also deviated from the estimated LOE. Id.

We agree that the agency’s evaluation of this aspect of the awardee’s quotation was reasonable. The solicitation did not require vendors to adhere strictly to the agency’s estimated LOE or to explain deviations from the LOE. Rather the solicitation merely noted that the estimated LOE would be used as part of the evaluation. RFQ at 4. Moreover, as the agency notes, the protester also shifted four FTEs between tasks, a significantly more extensive deviation from the estimated LOE than the challenged shift in the awardee’s quotation. While the protester argues that its deviations were different because they were fully explained, and that the awardee’s deviations were insufficiently explained, the solicitation did not require vendors to provide explanations of deviations from the LOE. In this case, the agency used its business judgment to assess risk posed by deviations from the LOE and did so reasonably and even-handedly; the protester simply disagrees with the agency’s evaluation, which fails to provide an adequate basis on which to sustain the protest.

In response to the protester’s second argument, the agency notes that, because this is a task order issued under a BPA, all offerors were required to propose labor categories that were included in the BPA, but that those labor categories were broadly defined. Supp. MOL at 21-24. While the protester is correct that the awardee’s technical narrative identifies both job titles and lists labor categories, the agency understood the narrative, not as proposing additional unpriced FTEs, but rather as mapping the job titles onto the labor categories proposed. Id. This reading is reinforced by the fact that each task narrative section in the staffing plan included a chart identifying the number of FTEs proposed for each task and mapping those FTEs to labor categories, and those charts in the technical quotation match the price quotation exactly. Id. In light of those tables for each task area, the agency argues it would be irrational to read the awardee’s quotation as proposing large numbers of additional unpriced staff. Id.

In response, the protester notes that for certain tasks the awardee’s quotation identified more job titles than FTEs so the quotation cannot be reasonably read as mapping the job titles to the labor categories. Supp. Comments at 3-10. For example, for task one, the protester argues that the awardee’s proposal lists only two FTEs, but the narrative discusses three different job titles. Id. Similarly, the protester contends that some of the job titles cannot reasonably map onto the labor categories identified and the narrative appears to contemplate separate roles for those job titles. Id. For example, the awardee’s quotation describes, among other things, a data center operations manager and a data center engineer for task four, but the relevant labor categories proposed are for “IT specialists” and a “task/project manager.” Id. The protester argues that those roles cannot be reasonably encompassed by those labor categories and so they necessarily represent separate positions proposed by the awardee. Id. Moreover, the protester argues that the awardee’s narrative for task four contemplates that those roles are to perform distinct functions from the labor categories, and therefore they represent distinct, unpriced positions. Id.

We do not believe that the protester’s reading of the awardee’s quotation is a reasonable one and cannot conclude that the awardee’s quotation is inconsistent in the way the protester suggests. We concur with the agency that the inclusion of a table of the FTEs and labor categories for each task in the management approach quotation makes it clear that the awardee’s narrative is primarily mapping job titles to labor categories. Put another way, adopting the protester’s reading would require us to conclude that the awardee proposed, in effect, double the staff, but only priced half of it, which is implausible. Moreover, other indicia within the awardee’s quotation make it clear that the job titles are intended to map to the labor categories and do not, in general, represent separate positions. For example, the protester argues that the data center operations manager role discussed for task four is distinct from the task/project manager labor category position proposed for task four. See Supp. Comments at 4. However, the awardee’s key personnel include an individual whose resume indicates that he is being proposed for a position titled “Data Center Operations Mgr,” and with a labor category of “Task/Project Mgr.” AR, Tab I.2.1, IgniteAction Revised Technical Quotation at 36. That is, the quotation is unambiguous that the data center operations manager and the task/project manager are the same individual, and this further reinforces the reasonableness of the agency’s reading of the awardee’s quotation as mapping job titles to labor categories.[4]

Finally, with respect to task one, the protester is correct that the awardee identifies at least three job titles and only two FTEs. The protester appears to concede that two of the job titles for task one could map to the two labor categories identified, but the protester argues that the awardee’s quotation also discusses project control analysts that are not included in the priced labor for task one. See Id. at 14. However, the awardee’s quotation notes that it has significant indirect or back-office support staff in its business operations division that will support the effort. Id. at 1-5. Included in the list of functions performed by that business operations division in the quotation is “project control.” Id. at 3. Based on those features of the quotation, the agency argues, convincingly, that it understood those project control analysts to be business operations support staff not directly billable to the agency, analogous to human resources or security personnel also discussed as support functions.[5] Supp. MOL at 19. Such a reading is reasonable and consistent with the awardee’s quotation, and we see no basis to conclude that the agency erred in this regard.

Best-Value Tradeoff

Finally, the protester argues that the agency artificially equated different features of quotations and, in effect, impermissibly converted the best-value tradeoff into an LPTA basis of award. Supp. Comments at 10-18. For example, the protester notes that it proposed a 1-day transition plan which was necessarily lower risk than the awardee’s 55-day transition plan. Comments and Supp. Protest at 14. Moreover, the protester explains that it maintained a 100 percent retention rate, while the awardee’s retention rate was only 90 percent. Supp. Comments at 12. The protester contends that the best-value tradeoff failed to reasonably consider these differences between the quotations, flattening these and other technical advantages and, in effect, making award on an LPTA basis. Id. at 18.

Where, as here, a procurement conducted pursuant to FAR subpart 8.4 provides for issuance of an FSS task order on a best-value tradeoff basis, it is the function of the source selection authority to perform a price/technical tradeoff; that is, to determine whether one quotation’s technical superiority is worth its higher price. VariQ Corp., B‑409114 et al., Jan. 27, 2014, 2014 CPD ¶ 58 at 14. Even where a solicitation issued under FAR subpart 8.4 emphasizes technical merit over price, an agency properly may select a lower-priced, lower-rated quotation if the agency reasonably concludes that the price premium involved in selecting a higher-rated, higher-priced quotation is not justified in light of the acceptable level of technical competence available at a lower price. Id. at 15. The extent to which technical superiority is traded for a lower price is governed only by the test of rationality and consistency with the stated evaluation criteria. Id.

In this case, both of the aspects that the protester argues the agency failed to consider were documented as part of the agency’s evaluation. For example, the agency’s best- value determination memorandum explicitly noted that other vendor’s quotations had technical advantages over the awardee, and specifically discussed the protester’s “comparatively higher incumbent retention rate,” but went on to conclude that there was “was no benefit so significant that justified paying millions of dollars as a price premium.” AR, Tab G.4, Best-Value Determination Memorandum at 6. Moreover, the memorandum also noted that IgniteAction had superior employee training to the protester, which could mitigate the risk of a lower retention rate. Id. at 7.

While the best-value memorandum did not specifically discuss the difference in transition periods, the source selection authority noted that he reviewed the technical quotations and the technical evaluation report and concurred in the analysis of the technical evaluators. Id. The source selection authority went on to note that, while there were various differentiating benefits of quotations other than IgniteAction’s quotation, there were no significant benefits that merited paying a significant price premium. Id. In this regard, the technical evaluators concluded that the protester’s shorter transition period likely presented “a lower risk of service degradation during the initial few months of the contract,” and posed “minimal risk” to operations. AR, Tab G.1., Consensus Technical Evaluation Report at 2. However, as discussed above, the technical evaluation team did not view this aspect of the protester’s quotation as meriting special recognition. Id. While the source selection authority did not identify this aspect of the protester’s quotation specifically as a non-discriminator, an agency is not required to document determinations of adequacy, especially where, as here, the source selection authority is merely adopting the conclusions of the technical evaluation team. We see no basis to question the agency’s overall conclusion that this aspect of the protester’s quotation did not represent a significant differentiator.

To summarize, contrary to the protester’s suggestion that the agency effectively awarded on an LPTA basis, the best-value decision memorandum is clear that the agency performed a best-value tradeoff by considering whether the technical advantages of some quotations merited paying a price premium. Indeed, while all quotations received the same adjectival ratings, the agency looked behind those ratings to note specific technical advantages of quotations, such as the protester’s retention rate or the awardee’s training program. AR, Tab G.4, Best-Value Determination Memorandum at 6-7. Ultimately, the agency concluded that it could not justify paying a $6,170,701.86, or 14 percent, price premium for the technical advantages of the protester’s quotation, which is the essence of a best-value tradeoff. In short, the record reflects that the agency performed a reasonable best-value tradeoff among competing quotations.

The protest is denied.

Edda Emmanuelli Perez
General Counsel