TechSur Solutions, 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: TechSur Solutions, LLC

File: B-423812.3; B-423812.4

Date: August 11, 2026

Meghan D. Doherty, Esq., John E. Jensen, Esq., Dinesh C. Dharmadasa, Esq., and Alexis P. Landrum, Esq., Pillsbury Winthrop Shaw Pittman LLP, for the protester.
Amy L. O'Sullivan, Esq., Cherie J. Owen, Esq., and Issac D. Schabes, Esq., Crowell & Moring LLP, for Accenture Federal Services, LLC, the intervenor.
Julie A. Neville, Esq., Administrative Office of the United States Courts, for the agency.
Sarah T. Zaffina, Esq., and Alexander O. Levine, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Protest challenging establishment of a blanket purchase agreement is denied where the record demonstrates that the agency reasonably determined that labor categories required by the solicitation fall within the scope of the labor categories quoted by the awardee from its multiple award schedule contract.

DECISION

TechSur Solutions, LLC, a small business of Reston, Virginia, protests the establishment of a blanket purchase agreement (BPA) with, and the issuance of a call order to, Accenture Federal Services, LLC (AFS), of Arlington, Virginia, under request for quotations (RFQ) No. USCA25Q0147, issued by the Administrative Office of the United States Courts (AOC), for information technology (IT) support services for the Judiciary Data & Analysis Office (JDAO) Enterprise Data Warehouse (EDW). The protester argues that the agency unreasonably evaluated quotations and made an unreasonable source selection decision.

We deny the protest.

BACKGROUND

On February 28, 2025, the agency issued the RFQ to 14 contractors through the General Services Administration (GSA) eBuy system under federal supply schedule (FSS) multiple award schedule (MAS) categories 54151S, IT professional services, and 518210C, cloud computing and cloud related IT professional services.[1] Contracting Officer's Statement (COS) at 1; see also Agency Report (AR), Tab 3, Conformed RFQ at 23, 31. In general terms, the successful vendor will provide the AOC with IT services in eight functional areas. These generally include providing support for the current IT tools that interact with data for which JDAO is responsible, modernization and development of new services, and research and consultation for a new cloud service provider that will be the subject of a future procurement.[2] See generally Conformed RFQ at 4-12. The RFQ contemplated the establishment of a single BPA that had a base year and four 1-year options, along with the issuance of an initial call order for operations and maintenance services of the EDW. Conformed RFQ at 16; AR, Tab 3.1, RFQ amend.1, attach. 5, BPA Call Order SOW at 1. The BPA will issue call orders that are fixed-price, labor-hour, time and materials, or a hybrid; here, the BPA call order is a labor-hour order. Conformed RFQ at 3, 22, 27; AR, Tab 3.1, RFQ amend. 1, attach. 1, BPA Pricing Workbook at tab 3, BPA Call Order, A15.

The RFQ provided that a single BPA would be established pursuant to Federal Acquisition Regulation (FAR) section 8.405-3, on a best-value tradeoff basis with the responsible vendor whose quotation conforms to the solicitation and “is determined to represent the best overall value to the [g]overnment and lowest cost alternative (considering price, special features, administrative costs, etc.) to meet the [g]overnment's needs.” Conformed RFQ at 3, 29. The RFQ indicated that quotations would be evaluated under three evaluation factors: (1) technical; (2) past performance; and (3) price. Id. at 29. Technical was more important than past performance, and when combined, technical and past performance factors were significantly more important than price. Id. The RFQ stated that the agency may make tradeoffs between technical superiority and price when deciding which vendor's quotation is the best value. Id.

The RFQ informed vendors that, for the non-price factors, the agency would evaluate the level of confidence it has that the vendor understands the requirements, proposes a “sound approach,” and will successfully perform the requirements. Id. at 30. The RFQ advised vendors that their technical quotation would be comprised of an oral presentation consisting of a slide presentation and interactive dialogue addressing the vendor's ability to perform the eight functional categories of the BPA and the call order successfully.[3] Id. at 24-25. For the past performance factor, the RFQ instructed vendors to submit four examples of projects performed within three years from the solicitation's issue date. Id. at 25. The agency would evaluate the submissions for relevancy and assign each submission a rating of very relevant, relevant, somewhat relevant, or not relevant. Id. at 29‑30. The RFQ indicated that only recent and relevant submissions would be considered in the overall performance confidence rating.[4] Id.

For the price quotation, the solicitation instructed each vendor to complete and submit a pricing workbook provided with the solicitation. Id. at 26-27; AR, Tab 3.1, RFQ amend. 1, attach. 1, BPA Pricing Workbook. For the BPA, the pricing workbook was to include, among other things, the vendor's proposed MAS labor categories and labor rates, including any discounts from its existing MAS contract pricing. Conformed RFQ at 26‑27. The RFQ also required the vendor to include labor categories and proposed hours for the call order and a crosswalk of the corresponding labor categories in the vendor's MAS contract with an explanation of how the quoted labor categories related back to the RFQ labor categories. Id. at 27. The agency would evaluate the price quotations to determine whether the pricing workbook was completed correctly, whether the proposed labor categories were on the vendor's MAS contract under the 54151S and 518210C categories, and whether the quoted labor rates were equal to, or less than, the schedule rates. Id. at 31. The agency would further evaluate whether “[t]he quoted price for the BPA [c]all is fair and reasonable,” and compare the quoted labor categories with the vendor's technical quotation. Id.

In response to the solicitation, the agency received nine quotations. COS at 3. The agency determined TechSur's quotation was the best value and held exchanges with TechSur. Id. at 8. After evaluating TechSur's final revised quotation, the agency established a BPA with TechSur, and two firms filed protests with our Office challenging the agency's selection decision. Id.

In response to those protests, the agency advised our Office that it intended to take corrective action by reevaluating quotations, documenting a new best-value tradeoff analysis, and making a new selection decision. Based on the agency's proposed corrective action, we dismissed those protests as academic. Gunnison Consulting Grp., Inc., B-423812, Sept. 11, 2025 (unpublished decision); Salient CRGT, Inc., B-423812.2, Sept. 11, 2025 (unpublished decision).

The agency reevaluated all quotations received and requested final quotation revisions from five vendors that “had shown through their past performance examples that they were capable of providing the required services.” COS at 17. Following the evaluation of final revised quotations, the agency assigned AFS and TechSur the following ratings.[5]

	AFS	TechSur
Technical	High	High
Past Performance	Substantial Confidence	Satisfactory Confidence
Evaluated Price (BPA Call Order)	$2,997,331	$3,037,543

AR, Tab 9, Award Decision Document at 48. The contracting officer, who was the source selection authority (SSA), conducted a comparative assessment of the quotations and determined that establishing a BPA with AFS was in the best interests of the government because its quotation offered the most technical benefits, with the least risk of unsuccessful performance, and was the lowest priced of the highest technically rated quotations.[6] Id. at 51-52; COS at 26.

On April 22, 2026, AOC selected AFS for the BPA and notified all unsuccessful vendors. AR, Tab 10, Notice of Unsuccessful Vendor. On April 24, the agency provided TechSur with a brief explanation of the selection decision in accordance with FAR section 8.405-2(d). AR, Tab 11, Brief Explanation of Award. This protest followed.[7]

DISCUSSION

TechSur raises various arguments challenging AOC's evaluation of quotations.[8] The protester argues the agency's evaluation of price quotations was contrary to law and inconsistent with the solicitation criteria. TechSur also contends that AFS should be ineligible for award because its MAS contract does not include the labor categories required by the RFQ. Protest at 11-16. AOC responds that its evaluation was consistent with the solicitation terms and that it reasonably interpreted AFS's proposed labor categories to cover the required skills specified in the RFQ's labor categories. COS at 14-16; Memorandum of Law (MOL) at 10-14.

Where, as here, an agency issues a solicitation to FSS vendors under FAR subpart 8.4 and conducts a competition for the issuance of an order, our Office will not reevaluate the quotations; rather, we review the record to ensure that the agency's evaluation was reasonable and consistent with the terms of the solicitation and applicable procurement laws and regulations. FreeAlliance.com, LLC et al., B-419201.3 et al., Jan. 19, 2021, at 5. A protester's disagreement with the agency's judgment does not establish that an evaluation was unreasonable. DEI Consulting, B-401258, July 13, 2009, at 2.

For the reasons explained below, we deny the protest and find no basis to object to the agency's evaluation of quotations or selection decision.[9]

Price Evaluation

As an initial matter, TechSur disputes the agency's evaluation of price quotations as being contrary to law and inconsistent with the solicitation criteria. In this regard, the protester asserts that the agency was required to assess and compare the vendors' pricing for all of the labor categories under the BPA to establish a BPA with the vendor representing the best value to the government and the “lowest cost alternative (considering price, special features, administrative costs, etc.)[.]” Protest at 8-11; see also Conformed RFQ at 29. AOC contends that this protest ground is untimely because the RFQ clearly established the terms of the price evaluation, and the protester did not raise this challenge before the deadline for quotations. Partial Req. for Dismissal at 2‑4; see also 4 C.F.R. § 21.2(a)(1). The RFQ stated that after the agency confirmed that vendors had completed the pricing worksheets properly and that the labor categories were from the required MAS contracts with rates equal to or less than the maximum rates, the agency would evaluate whether “[t]he quoted price for the BPA Call is fair and reasonable which will include an analysis of the quoted labor mix as compared to [vendors']technical approach.” Conformed RFQ at 31.

The protester responds that it is not challenging the terms of the solicitation but the agency's failure to follow them. Resp. to Req. for Dismissal at 1-5. In this regard, the protester contends that the agency was required to consider vendors' BPA labor category pricing consistent with the RFQ's basis of award, which announced AOC's intent to establish a BPA with the “lowest cost alternative (considering price, special features, administrative costs, etc.) to meet the Government's needs.” Id. (citing Conformed RFQ at 29).

Where a dispute exists as to a solicitation's actual requirements, we begin by examining the plain language of the solicitation. Point Blank Enters., Inc., B-411839, B-411839.2, Nov. 4, 2015, at 4. We resolve questions of solicitation interpretation by reading the solicitation as a whole and in a manner that gives effect to all provisions; to be reasonable, and therefore valid, an interpretation must be consistent with such a reading. Desbuild, Inc., B-413613.2, Jan. 13, 2017, at 5. If the solicitation language is unambiguous our inquiry ceases; an ambiguity exists, however, where two or more reasonable interpretations of the solicitation are possible. Id.

Read as a whole, the solicitation establishes that only the BPA call order will be evaluated for price. Beyond ensuring that labor categories are on the correct MAS contract and that labor rates are equal to or less than vendors' MAS rates, the section of the solicitation outlining the evaluation factors only references the evaluation of the BPA call order price. Conformed RFQ at 31. Absent any reference to or discussion of an evaluation of price other than the BPA call order prices, it is not apparent what other prices the protester thought the agency would use to assess “low cost” or how they would be assessed. To the extent the protester contends that the agency should have considered the stand-alone BPA labor rates to determine “low cost” there is no explanation in the solicitation for how a “low cost” would be determined from mere labor rates that are untethered from any quantity of hours, which were not included in the solicitation. We have explained that evaluating prices for unit prices without quantities can lead to unreasonable evaluation results. See, e.g., R&G Food Serv., Inc., d/b/a/ Port-A-Pit Catering, B-296435.4, B-296435.9, Sept. 15, 2005, at 7 (sustaining protest where agency unreasonably evaluated prices on an indefinite-quantity contract based on unit prices without also considering the estimated quantities of each item). To evaluate prices where quantities are unknown, agencies have developed a variety of methods, including for example, the use of sample orders, or, as in this case, using the evaluation of an actual order as the basis for the price evaluation. See Office Depot, LLC, B-420482, May 3, 2022, at 9. Accordingly, the protester's interpretation of the solicitation is without a reasonable basis and we deny this aspect of the protest.[10]

Next, TechSur argues that the selection of AFS for the BPA and the call order was improper because AFS's MAS contract does not include labor categories that align with the labor categories required by the solicitation. Protest at 11-16; Comments & Supp. Protest at 8‑14. In this regard, the protester asserts that three of the labor categories quoted by AFS from its MAS do not encompass the skills, or meet the education and experience requirements, of the corresponding RFQ labor categories. Protest at 11-16; Comments & Supp. Protest at 8‑14. The agency contends that it reasonably decided the RFQ requirements are within the scope of the MAS labor categories proposed by AFS. COS at 14-16; Supp. COS at 1-3; MOL at 10-14. As discussed below, we find no basis to sustain TechSur's protest.

Where an agency announces its intent to order from an existing FSS, all items quoted and ordered are required to be on the vendor's schedule contract as a precondition to it receiving the order. Ruchman & Assoc., Inc., B-415400 et al., Jan. 2, 2018, at 5-6. When a concern arises that a vendor is offering services outside the scope of its FSS contract, the relevant inquiry is whether the services offered are actually included on the vendor's FSS contract, as reasonably interpreted. Id.; Professional Analysis, Inc., B‑419239, B‑419239.2, Jan. 8, 2021, at 4. To determine this, our Office will consider whether the function being sought under a particular solicitation is the same as the function covered under the vendor's schedule contract. Advantaged Sols., Inc., B‑418790, B-418790.2, Aug. 31, 2020, at 5‑6. Additionally, we have recognized that an FSS labor category, detailing a minimum number of years of experience that is below that required by the corresponding labor category in the solicitation, can still be within the scope of the solicitation labor category. LOGMET LLC, B-422200, B-422200.2, Feb. 21, 2024, at 6‑7 (citing Grant Thornton, LLC, B‑416733, Nov. 20, 2018, aff'd., Dept. of Defense, Recon., B‑416733.2, Mar. 18, 2019). In this regard, we have stated that because the years of experience required for the FSS labor category is a minimum, nothing prevents vendors from providing personnel with more than that level of experience. Id. (finding the fact that the awardee's FSS labor categories required a minimum years of experience requirements below those required by the solicitation was not, on its own, a reason to sustain the protest).

Here, as explained above, the RFQ required vendors to submit pricing schedules that included, among other information, quoted labor categories from their underlying MAS contracts and pricing information. RFQ at 31. The solicitation stated that vendors “are responsible, without prompting from the [g]overnment, for including enough detail to permit a complete and accurate evaluation of their quotation.” Id. at 29. Quotations were also required to include a crosswalk between the solicitation's labor categories and the vendor's MAS contract labor categories that explained how the quoted labor categories mapped back to the requirements for the solicitation's labor categories. Id. at 27.

The solicitation identified 15 labor categories to be used in performance of call orders issued against the BPA and included descriptions with associated qualifications, minimum experience requirements, and minimum education requirements. Conformed RFQ attach. 2, Labor Category Descriptions; AR, Tab 3.1, RFQ amend. 1, attach. 1, BPA Pricing Workbook at tab 4, Labor Mapping. The pricing workbook identified different skill levels required for each labor category and the corresponding required minimum education and years of experience. Id. For example, the solicitation provided that a mid-level position required a bachelor's degree, or higher degree, and a minimum of three to five years of relevant experience. Conformed RFQ attach. 2, Labor Category Descriptions at 2. The solicitation also provided that years of experience could be substituted for education.[11] Id.

AFS's quotation included the required crosswalk of labor categories from its MAS contract mapped to the solicitation's labor categories. Supp. AR, Tab 3, AFS Price Quotation at tab 4, Labor Mapping. AFS's crosswalk included a description of its quoted labor category skills and a rationale for why that labor category matched the solicitation's labor category. Id.

The SSA advised the TET to review each firm's quoted labor categories to determine whether the solicitation's services could be “reasonably interpreted” as including the quoted labor categories. COS at 14; Supp AR, Tab 4, Decl. of TET Chairperson at 2-3. The SSA further instructed the TET to only document an analysis of quoted labor categories if a labor category did not meet the solicitation's labor category requirements; therefore, the TET did not document quoted labor categories that met the RFQ's labor categories. COS at 14.

The TET found that “the GSA labor categories quoted by [AFS] can be reasonably read to include the tasks required by the RFQ and contained in the [AOC] suggested labor categories.”[12] AR, Tab 9, Award Decision Document at 3. In the award decision, the SSA concurred with the TET's findings and stated that AFS's quoted labor categories and level of effort “did not raise concerns.”[13] Id. at 47.

TechSur alleges that AFS quoted three labor categories from its MAS contract that do not encompass the required skills, minimum education, and minimum experience of the solicitation's labor categories. The protester contends that the agency's evaluation of these labor category alignments was unreasonable and undocumented. Protest at 11‑16; Comments & Supp. Protest at 8‑14. The three RFQ labor categories that the protester alleges are outside the scope of AFS's MAS contract are: (1) senior application developer; (2)  senior quality assurance analyst; and (3) extract, transform, load or extract, load, transform (ETL/ELT) developer. Protest at 11-16; Comments & Supp. Protest at 8‑14.

TechSur first challenged the two labor categories AFS quoted (senior application developer and senior quality assurance analyst) on the basis that AFS's MAS contract did not meet the RFQ's minimum education and experience levels for these labor categories. Protest at 11-16; Comments & Supp. Protest at 8‑14. The agency argues that AFS's proposed MAS labor categories represent minimum years of experience and minimum education levels such that AFS is capable of providing personnel with greater experience and education level to meet the solicitation's requirements in performing the call order because the education and experience levels represent a floor and not ceiling. MOL at 10-12. The protester disputes the agency's acceptance of AFS's minimum labor categories without an affirmative indication from AFS to meet the higher education and experience RFQ requirements. Comments & Supp. Protest at 10-12; Supp. Comments at 2-4.

We find the agency's evaluation to be reasonable. Because the experience level for the MAS labor category is a minimum, it is necessarily within the scope of the corresponding solicitation labor category containing a higher minimum experience requirement. LOGMET LLC, supra, at 7 (finding the fact that the awardee's FSS labor categories had minimum years of experience requirements below those required by the solicitation was not, on its own, a reason to sustain the protest). We note that the solicitation here did not require an additional, affirmative showing from the vendor that it intends to meet the requirements of the RFQ labor categories and the record shows that AFS quoted labor categories with education and experience levels similar to those required by the RFQ. Cf. id. (explaining that the record need not contain an affirmative showing that the vendor intends to meet particular RFQ experience requirements, where it proposes schedule labor categories within the scope of the RFQ requirements, unless otherwise required by the solicitation), with ISHPI Info. Techs., Inc., B-420718.2, B‑420718.3, July 29, 2022, at 9-10 (sustaining protest where vendor introduced new, unmapped labor categories with educational and experience requirements far below those required by the solicitation because it was unreasonable for the agency to presume that the personnel quoted to perform a requirement would actually meet the RFQ's more stringent educational and experience requirements). Accordingly, we find the protester's argument to be without merit.

The protester raises a different challenge to AFS's quoted labor category for the ETL/ELT developer position. The RFQ described the responsibilities and requirements of the ETL/ELT developer position as follows:

Design, develop, test, and maintain complex data engineering processes and identify areas of optimizations. Responsible for gathering requirements, designing, documentation, implementation, and maintenance and support of complex data processes that may require transforming data as per the business rules. Collaborate with data analysts, business stakeholders, architects, and other developers to understand and implement data engineering processes using a variety of ETL/ELT tools and methods. Must be experienced with the various performance tuning, data modeling, and related techniques and must actively participate in developing solutions.

Conformed RFQ attach. 2, Labor Category Descriptions at 3. The RFQ identified three skill levels‑‑junior, mid-level, and senior‑‑for this labor category with corresponding minimum education and experience.[14] AR, Tab 3.1, RFQ amend. 1, attach. 1, BPA Pricing Workbook, at tab 4, Labor Mapping, A12-A14.

For the ETL/ELT developer labor category, AFS quoted the following MAS labor categories: engineer 1 (for the junior level); engineer 2 (for the mid-level); and engineer 3 (for the senior level). Supp. AR, Tab 3, AFS Price Quotation at tab 1, GSA PRICE, A12-14, B12‑B14. AFS explained that the engineer labor category aligned with the RFQ labor category because it has “similar technical requirements, responsibilities, level of autonomy and oversight required of the suggested labor category” and “[t]he [e]ngineer labor category is responsible for design, development, testing and maintenance of technical components.” Id. at tab 4, Labor Mapping, E11-E13.

The protester argues that the quoted engineer labor category fails to encompass the specialized functions required under the solicitation of an ETL/ELT developer. Comments & Supp. Protest at 12-13. TechSur contends that AFS's description of the engineer labor category is generic and cannot map to the specialized data development skills the solicitation requires, including the use of ETL/ELT tools and methods by personnel to “understand and implement data engineering processes.” Id. at 13 (quoting the description of the RFQ's labor category). TechSur also argues that there is no contemporaneous evaluation record of the agency's analysis of whether AFS's engineer labor category met the solicitation requirements. Id. at 13-14.

The agency responds that the award decision included findings that the TET considered AFS's quoted labor categories and level of effort, that the TET did not have concerns, and that the SSA concurred with the TET's findings. Supp. MOL at 6. The contracting officer, who was the SSA, explains that the TET was “instructed to only specifically document analysis for quoted labor categories that did not meet that standard, because if a labor category could not be reasonably interpreted to meet the requirements the quote would be determined unawardable.” COS at 14. The agency further explains that AFS's engineer labor category was reasonably interpreted to include the RFQ's ETL/ELT developer labor category because ETL/ELT “is the process of combining data from multiple sources into a large, central repository called a data warehouse.” COS at 15. The RFQ requires “a strong blend of programming, data architecture, and analytical skills, centering around data processes” for the ETL/ELT developer labor category. Id. at 16. The agency asserts that the description of AFS's proposed engineer labor category included “knowledge in design, architecture, development[,] and administration.” Id.; Supp. AR, Tab 3, AFS Price Quotation at tab 4, Labor Mapping, D11-D13.

We conclude that the agency reasonably evaluated and accepted AFS's proposed labor categories. In this regard, the agency considered the quoted labor categories from AFS's MAS contract and determined that they encompassed the RFQ's labor categories. As demonstrated in the example above, the agency considered AFS's quoting of an engineer labor category with “knowledge in design, architecture, development[,] and administration” to be broad enough to include the specialized ETL/ELT data skills required by the solicitation. COS at 15-16, AR, Tab 9, Award Decision Document at 3, 47. While the engineer labor category was broader than the ETL/ELT developer position, we find that the agency properly concluded that the functions of the latter position could be encompassed within the description of the engineer position. See Ruchman & Assoc., supra (denying protest where agency reasonably interpreted awardee's proposed labor category skills to meet the agency's requirements).

Although the protester claims that we should give no weight to the agency's post-protest explanations, our Office generally considers such statements where the explanations merely provide a detailed rationale for contemporaneous conclusions and fill in previously unrecorded details, so long as the explanations are credible and consistent with the contemporaneous record. Arrington Dixon & Assocs., Inc., B-409981, B‑409981.2, Oct. 3, 2014, at 8. Here, the contracting officer's statements and the agency's MOL are consistent with, and provide a more detailed explanation of, the award decision. The procedures under FAR subpart 8.4 provide for a streamlined procurement process with minimal documentation requirements. FAR 8.405-2(f); Citizant, Inc.; Steampunk, Inc., B-420660 et al., July 13, 2022, at 19. In addition, while source selection decisions must be documented and have a reasonable basis, an agency is not necessarily required to document all “determinations of adequacy.” Allied Tech. Group, Inc., B-412434, B-412434.2, Feb. 10, 2016, at 13. In the contemporaneous record, only areas of concern in the vendors' quotations were documented, and here neither the TET nor the SSA raised concerns regarding whether AFS's labor categories reasonably included the skills required by the RFQ's labor categories. COS at 14; AR, Tab 9, Award Decision Document at 3, 47. Further, the contracting officer's statement and the MOL discuss in detail the requirements for the labor categories and explain how the categories proposed by AFS meet the RFQ's requirements. COS at 15-16; MOL at 10‑14. Although TechSur disagrees with the agency's conclusions, the protester has not shown that the requirements of the RFQ positions were not reasonably encompassed by AFS's proposed labor categories. DEI Consulting, supra. (a protester's disagreement with an agency's judgment does not establish that an evaluation was unreasonable).

The protest is denied.

Edda Emmanuelli Perez
General Counsel

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