T3i, Inc.

DOCUMENT FOR PUBLIC RELEASE

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

Decision

Matter of: T3i, Inc.

File: B-423815

Date: December 30, 2025

Kristin E. Zachman, Esq., and Johnathan M. Bailey, Esq., Cokinos Young, for the protester.
William A. Shook, Esq., The Law Offices of William A. Shook PLLC, for LMR Technical Group, LLC, the intervenor.
Sanique J. Balan, Esq., Colonel Justin Silverman, Beatrice K. Foster, Esq., David J. Dusseau, Esq, and Susan E. Bond, Esq., Department of the Air Force, for the agency.
Thomas J. Warren, Esq., and Alexander O. Levine, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Protest that agency unreasonably rejected protester's proposal based on unrealistic pricing is denied where the record shows that the agency's price realism analysis was reasonable and consistent with the solicitation.

DECISION

T3i, Inc., a small business of San Antonio, Texas, protests the issuance of a task order to LMR Technical Group, LLC, of Dallas, Texas, under task order proposal request (TOPR) No. FA489025R0023, issued by the Department of the Air Force, Air Combat Command, for non-personal support services. T3i alleges that the agency conducted an unreasonable price realism evaluation and improperly excluded T3i from the competition.

We deny the protest.

BACKGROUND

On May 13, 2025, the agency issued the TOPR in accordance with Federal Acquisition Regulation (FAR) section 16.505 to firms holding the Air Force's Human Performance Optimization (HPO) multiple-award, indefinite-delivery, indefinite-quantity (IDIQ) contract. Agency Report (AR), Tab 4, TOPR at 1.[1] The solicitation was issued to support the Air Force's comprehensive readiness for aircrew flying training (CRAFT) program, which is intended to maintain and advance the unique cognitive, emotional, and physical performance needs of modern Air Force aircrews. AR, Tab 5, Performance Work Statement (PWS) at 4. In this regard, the TOPR seeks to acquire non-personal support services tailored to the needs of student aircrews and instructor pilots to “support curriculum refinement, technology integration, facility improvements, and outcome tracking” for the CRAFT program across the Air Education and Training Command (AETC) flying training enterprise. Id. at 4-5. Under the terms of the task order, the selected contractor must fill 129 full-time equivalent (FTE) positions at 13 different AETC headquarters locations. Id. at 47-49; Contracting Officer's Statement (COS) at 2.

The solicitation contemplated the issuance of a fixed-price, level-of-effort task order with fixed-price and cost-reimbursable contract line item numbers. TOPR at 1. The task order would be performed over a 1-year base period, four 1-year option periods, and one 6-month extension period. Id. The task order would be issued on a lowest-price, technically acceptable basis to the offeror whose total evaluated price (TEP) was determined to be fair, reasonable and balanced, and “whose prices are realistic for the work to be performed and reflect a clear understanding of the contract requirement.” Id. at 2‑3.

The TOPR instructed offerors to include specific information in their proposals. Id. at 3‑5. Relevant here, the solicitation attached a spreadsheet document that identified each of the 129 FTEs by position title, location and the respective PWS task that each position would support. Id.; AR, Tab 6, TOPR attach. 3 at 10-21. Offerors were instructed to include, in this spreadsheet, “pricing for all work required to execute all PWS requirements.” TOPR at 4. Specifically, offerors were to include a “complete breakdown of all direct and indirect costs factored into the total pricing for each FTE in their designated location,” including “hourly labor rates (unburdened) and hourly labor rates (burdened).” Id. Offerors were also instructed to include all pricing for the base year and all option periods under each contract line item number. Id. at 4-5. Finally, offerors were instructed to “[p]rovide a narrative with all supporting documentation for the proposed prices and rates, including any assumptions made, to show how the pricing was developed.” Id. at 4.

The agency's evaluation of task order proposals would follow a sequential process. Id. at 2. First, for the technical portion of the evaluation, an offeror's proposal would be evaluated as acceptable if the offeror “proposes the correct number of FTEs” identified in the solicitation. Id. at 3. The agency would then evaluate each acceptable offeror's price proposal, and TEP, “for fairness, reasonableness, and balance.” Id. The offeror with the lowest TEP, and fair, reasonable, and balanced prices, would then “have [its] hourly labor rates (unburdened) evaluated for price realism[.]” Id. If the offeror's proposed unburdened hourly labor rates were “deemed unrealistic,” the offeror with the next lowest TEP would have its unburdened hourly labor rates evaluated for realism--and this process would continue “until an [o]fferor with realistic prices is identified.” Id. The solicitation specified the price realism evaluation methodology as follows:

The Government may use a variety of resources and methods to evaluate the realism of the Offeror's hourly labor rates (unburdened), including but not limited to: statistical analysis, comparing prices paid on prior or similar contracts, comparison of proposed pricing from multiple Offerors, market data from one or multiple sources (e.g., Watson & Wyatt, Economic Research Institute [(ERI)], Bureau of Labor Statistics, Salary.com, etc.), or a combination of the above. The Offerors' proposed prices may be evaluated at detailed or aggregate levels, or both.

TOPR at 5.

The Air Force received six proposals prior to the June 16 closing date for receipt of proposals, including proposals from T3i and LMR. AR, Tab 8, Fair Opportunity Decision Document (FODD) at 3. In its evaluation, the agency determined that the proposal submitted by T3i included 129 FTEs, as required, and was thus technically acceptable. Id. The agency also found that T3i had the lowest TEP at $73,629,857, with a price that was fair, reasonable, and balanced. Id. The agency then evaluated the realism of T3i's unburdened hourly labor rates for each of the proposed 129 FTE positions. Id.

When evaluating T3i's unburdened hourly labor rates, the agency determined that 25 of the 129 proposed unburdened hourly labor rates were unrealistically low. Id. at 9. As a result, the agency excluded T3i from the competition. Id. The agency then evaluated the unburdened hourly labor rates of LMR, the next-lowest priced technically acceptable offeror, with a TEP of $77,562,916. Id. at 3-4, 9. The Air Force determined that LMR's TEP was reasonable and balanced and its unburdened hourly labor rates were realistic; consequently, the Air Force issued the task order to LMR. Id. at 16; COS at 6.

On July 30, the agency notified T3i and included a written debriefing explaining that T3i was excluded from consideration on the basis that the firm's proposed unburdened hourly labor rates were unrealistically low. Protest at 7-8; AR, Tab 9, Notice of Unsuccessful Offer and Debrief at 1-7. This protest followed.[2]

DISCUSSION

T3i alleges that the Air Force performed a flawed price realism analysis and improperly concluded that T3i's proposed unburdened hourly labor rates were unrealistic. The protester also argues that the agency applied unstated evaluation criteria when comparing T3i's unburdened hourly labor rates to a labor category not identified in the solicitation. Although we do not address every argument, we have reviewed them all and find no basis to sustain the protest.

We note, at the outset, that in reviewing a protest challenging an agency's evaluation in a task order competition, 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. IBM Corp., IBM Consulting--Fed., B-421471, et al., June 1, 2023, 2023 CPD ¶ 135 at 7. Rather, we examine the supporting record to determine whether the agency's evaluation was reasonable and consistent with the stated evaluation criteria and applicable procurement laws and regulations. AKAL Sec., Inc., B-417840.4, Apr. 27, 2020, 2020 CPD ¶ 160 at 5. A protester's disagreement with the agency's judgment, without more, is insufficient to establish that the evaluation was unreasonable. Id.

Price Realism

T3i alleges that the Air Force conducted an unreasonable price realism evaluation. Specifically, the protester asserts that the agency's price realism analysis ignored relevant information in T3i's proposal justifying the firm's proposed unburdened hourly labor rates. Protest at 12-13. In this regard, T3i argues that the solicitation required proposals to include a pricing narrative, and other supporting price data, to explain offerors' unique pricing assumptions and to demonstrate their understanding of the work. Id. The protester contends that had the Air Force considered T3i's pricing narrative and supporting documentation in conducting the price realism analysis, the agency would have concluded that T3i's “technical approach could be achieved for the price it proposed.” Id.

Where a solicitation contemplates the award of a fixed-price contract or task order, including a fixed-price, level-of-effort task order, as here, an agency may provide for the use of a price realism analysis for the limited purpose of measuring an offeror's understanding of the requirements or to assess the risk inherent in the offeror's proposal. See, e.g., NTT DATA Servs. Fed. Gov't., Inc., B-417235.2, B-417235.3, Jan. 2, 2020, 2020 CPD ¶ 19 at 3; see also Amaze Techs., LLC, B-421002.2 et. al, May 8, 2023, 2023 CPD ¶ 98 at 12. The depth of an agency's price realism analysis is a matter within the sound exercise of the agency's discretion, and we will not disturb such an analysis unless it lacks a reasonable basis. Apogee Eng'g, LLC, B-414829.2, B‑414829.3, Feb. 21, 2019, 2019 CPD ¶ 85 at 8-9. Further, it is axiomatic that an agency's price evaluation must, at a minimum, comport with the terms of the solicitation. Digital Techs., Inc., B-406085, B‑406085.2, Feb. 6, 2012, 2012 CPD ¶ 94 at 3. A protester's disagreement with the nature and extent of an agency's price realism methodology, however, does not provide a basis on which to sustain a protest. See Sprezzatura Mgmt. Consulting, LLC, B‑420858.2, Mar. 6, 2023, 2023 CPD ¶ 100 at 6.

Here, the Air Force's price realism evaluation method involved comparing T3i's unburdened hourly labor rates to market average rates that the agency established for each of the 129 positions. As relevant background, the solicitation used a three-level tier framework for labor category classification purposes, with each position identified as either level 1, level 2 or level 3. AR, Tab 13, Decl. of Program Manager at 2; AR, Tab 5, PWS at 47‑49. The agency's realism evaluation used two different calculations to establish a comparative rate for each position.

For all level 1 positions, which comprise 108 of the 129 total positions, the agency calculated a market average rate, for each identified position, using published market data from ERI. In this regard, the agency obtained ERI data that identified both the “mean” rate and the “75th percentile” salary rate for each level 1 position. The agency then calculated a single market average rate for each position, to use for comparison purposes, by averaging the ERI mean and 75th percentile rates.[3] AR, Tab 8, FODD at 5; COS at 9. When conducting the price realism evaluation for the level 1 positions, the Air Force compared each of T3i's proposed unburdened hourly labor rates to the agency's market average rate. AR, Tab 8, FODD at 4-9. The agency found T3i's proposed labor rate to be unrealistic if the rate was more than 10 percent below the agency's market average. Id. at 4. For level 1 positions, the agency concluded that 4 of T3i's proposed labor rates were unrealistic. Id. at 5-6.

For the level 2 and level 3 positions, the agency used data obtained through ERI and Salary.com to create a rate “range” for each position--comprised of a low “base” rate and a “high” rate.[4] AR, Tab 8, FODD at 8. For the price realism evaluation for these positions, the agency compared T3i's proposed labor rates to this range, finding a labor rate to be unrealistic if the rate was more than 10 percent below the agency's “base” rate. Id. For level 2 and level 3 positions, the agency concluded that 21 of T3i's proposed labor rates were unrealistic. Id. at 8.

In sum, after applying this evaluation standard to each of T3i's proposed unburdened hourly labor rates, the agency determined that 25 of T3i's 129 proposed rates “posed a significant risk for the work to be performed and did not reflect a clear understanding of the contract requirements.”[5] Id. at 9.

T3i first argues that the agency unreasonably failed to consider T3i's pricing narrative in conducting the price realism analysis, as was required by the solicitation. Protest at 12‑13; Comments at 1-6. The Air Force responds by noting that it reviewed and considered T3i's pricing narrative as part of the price evaluation but did not consider the narrative as part of the agency's evaluation of the realism of unburdened labor rates. COS at 8. The agency explains that the solicitation limited the price realism analysis to an evaluation of the offeror's proposed unburdened hourly labor rates and did not require the agency to consider offerors' narratives as part of the price realism analysis. Id.; MOL at 8-9. The Air Force argues that its evaluation of these rates was consistent with recognized price analysis techniques set forth in FAR subsection 15.404-1(b)(2) and the terms of the solicitation. MOL at 4-11.

Based on our review of the record, we find that the Air Force conducted a reasonable price realism evaluation consistent with the terms of the solicitation. As an initial matter, we note that agencies have discretion to determine realistic prices by, among other techniques, comparing proposed prices against published price lists or by comparing proposed prices with prices obtained through market research for the same or similar items. See FAR 15.404-1(b)(2)(iv), (vi). The record demonstrates that the Air Force combined these techniques in its evaluation of the realism of T3i's unburdened hourly labor rates. See AR, Tab 8, FODD at 5-9; AR, Tab 13, Decl. of Program Manager at 2‑3; COS at 8‑14.

In addition, we find that the Air Force's price realism evaluation was consistent with the terms of the solicitation, which specified that the agency would evaluate the offerors' proposed unburdened hourly labor rates. As noted by the protester, the solicitation requested that offerors provide various price data in their price proposal, including burdened and unburdened rates, indirect cost breakdowns, and a pricing narrative. TOPR at 4-5. For the price realism evaluation, however, the solicitation only stated that the agency would evaluate each offeror's proposed unburdened hourly labor rates. Id. at 3 (explaining that the offeror with the lowest TEP would “have their hourly labor rates (unburdened) evaluated for price realism” and “[i]f the proposed hourly labor rates (unburdened) [] is deemed unrealistic,” the offeror with the next lowest TEP will be evaluated). In sum, the solicitation allowed the agency wide discretion to use a “variety of resources and methods” to conduct the realism analysis, but specified that the Air Force's chosen resources and methods would be used “to evaluate the realism of the Offeror's hourly labor rates (unburdened)[.]” Id. at 5.

The protester asserts that the solicitation requirement for proposals to include a pricing narrative obligated the agency to consider this narrative when the agency conducted the price realism evaluation. Protest at 12-13; Comments at 1-6. We disagree. Absent a specific provision in a solicitation, agencies are not required to conduct price realism analyses using any particular methodology. NTT DATA Servs. Fed. Gov't., Inc., supra at 4. Here, however, specific provisions in the solicitation obligated the agency to evaluate T3i's proposed unburdened hourly labor rates. See TOPR at 3, 5. We see no similar solicitation language, nor does the protester identify any, requiring the agency to evaluate T3i's pricing narrative when conducting the price realism evaluation. Although T3i may argue that the agency's realism analysis would have been more effective had it evaluated T3i's pricing narrative, we see no basis to sustain a protest on this basis because, as noted above, the nature and extent of an agency's price realism analysis are matters within the agency's discretion. See Sprezzatura Mgmt. Consulting, LLC, supra at 6.

Additionally, we are not persuaded by the protester's argument that the agency was required to consider T3i's pricing narrative because the narrative represented T3i's unique “technical approach.” See Protest at 12-13; Comments at 3-6. In this regard, the protester notes that the solicitation required the pricing narrative to “includ[e] any assumptions made” and to provide sufficient detail “to ensure proposed pricing reflects the work necessary to fully execute all PWS requirements.” Comments at 4 (citing TOPR at 4). The protester argues that, consequently, the agency was required to consider T3i's pricing narrative because it represented T3i's unique “technical approach” to meeting the solicitation's requirements. See id. at 6; Supp. Comments at 10-13.

In making this argument, the protester urges that we apply our Office's decisions sustaining challenges to an agency's price realism evaluation where the agency fails to consider an offeror's unique technical approach. See, e.g., Alcazar Trades, Inc.; Sparkle Warner JV, LLC, B-410001.4, B-410001.5, Apr. 1, 2015, 2015 CPD ¶ 123 at 5‑6; Criterion Corp., B‑422309, Apr. 16, 2024, 2024 CPD ¶ 96 at 4-5 (sustaining protest challenging agency's failure to consider the awardee's unique technical solution when concluding that the awardee's proposed labor rates were unrealistic).

We find the protester's argument unpersuasive for several reasons. First, the solicitation expressly limited the evaluation to the agency's consideration of an offeror's proposed unburdened hourly labor rates while leaving it to the agency how to do so, noting simply that the agency would use “a variety of resources and methods,” including by comparing rates to ERI market data. TOPR at 4-5. Because of this clear solicitation language, to the extent that the protester now challenges the agency's failure to evaluate T3i's pricing narrative as part of the agency's price realism evaluation, the protester raises, in effect, an untimely challenge to the terms of the solicitation. 4 C.F.R. § 21.2(a)(1); Integrity Mgmt. Consulting, Inc., B‑417942, Dec. 16, 2019, 2020 CPD ¶ 49 at 4 (noting that to the extent the protester argued the agency was required to analyze individual labor categories as part of the agency's price realism analysis, such a challenge would be untimely because the solicitation was clear that the price realism evaluation would analyze only the firm's labor rates, not labor categories).

In addition, the solicitation did not require a substantive technical evaluation; to be considered technically acceptable, offerors were only required to propose all 129 FTE positions identified in the solicitation. TOPR at 3. Accordingly, the solicitation did not contemplate the evaluation of an offeror's unique technical approach. Instead, offerors were instructed to submit price proposals using the spreadsheet provided in the TOPR to include unburdened hourly labor rates for each of the 129 positions. Id. at 4. Our Office has explained that where, as here, a solicitation does not contemplate the evaluation of a unique technical approach, a price realism analysis that only compares labor rates is reasonable. See, e.g., Integrity Mgmt. Consulting, Inc., supra at 5; accord NTT DATA Servs. Fed. Gov., Inc, supra at 5; see also ACTA, LLC, B-418352, B‑418352.2, Mar. 17, 2020, 2020 CPD ¶ 107 at 6. (“[W]here, as here, a solicitation includes the labor categories, and hours that offerors are required to use to prepare their proposals, the agency may reasonably perform its price realism analysis by determining if the proposed rates are realistic without additional analysis.”).

Similarly, the solicitation here required offerors to submit unburdened hourly labor rates for all 129 positions. TOPR at 3-4. Although the solicitation did not also establish required labor hours, the agency's realism evaluation normalized any potential for variation in level-of-effort assumptions by adopting T3i's assumed labor hours. See AR, Tab 8, FODD at 8 (noting that market salaries were divided by T3i's proposed annual work hours to determine the agency's market average hourly labor rates). Accordingly, because the solicitation did not contemplate the evaluation of offerors' unique technical approaches, we see nothing improper about the agency limiting its realism analysis to an evaluation of T3i's unburdened hourly labor rates. See, e.g., Integrity Mgmt. Consulting, Inc., supra at 5.

Finally, we also are not persuaded by T3i's argument that its pricing narrative represented its unique technical approach in any meaningful sense. In our review of T3i's pricing narrative, the information presented was general in nature and did not provide any specific explanation for how T3i approached each proposed unburdened hourly labor rate. See generally AR, Tab 7, T3i's Pricing Narrative. Instead, the pricing narrative generally asserted that T3i's proposed rates were developed using market research, including data from ERI, and validated though T3i's labor surveys and experience. See id. at 5-8. Moreover, in the only section of the narrative addressing direct labor rates, T3i's analysis was similarly general. Id. at 10-11. For example, T3i's proposal stated that it “ ensures rate realism by keeping current with changes in the labor market” and by conducting a “detailed analysis and comparison of pay practices within the industry and relevant geographic labor markets.” Id. at 11. Beyond general statements such as these, T3i's pricing narrative did not, for example, specify how it intends to fill all of the positions to meet the solicitation's requirements while also proposing low unburdened hourly labor rates. In sum, on this record, we see no basis to conclude that the Air Force unreasonably failed to consider T3i's pricing narrative during the agency's price realism evaluation.[6] See ACTA, LLC, supra at 7, n.3 (denying protest allegation challenging an agency's failure to consider a protester's cost narrative, where the narrative “provide[d] no explanation [] of why [the protester's] rates are so much lower than the incumbent rates, or what any specific survey showed for any particular labor category”).

Unstated Evaluation Criteria

T3i also argues that the agency applied unstated evaluation criteria when conducting the price realism evaluation. In this regard, the protester asserts that the agency unreasonably compared T3i's proposed labor rates to an inapposite labor category, with a higher salary range, than what was required by the solicitation. Protest at 14-20; Comments at 7-12; Supp. Comments at 14-16. Specifically, T3i contends that the agency improperly used pricing data from an organizational psychologist labor category as a basis of comparison with 21 of T3i's unburdened hourly labor rates that the agency evaluated as unrealistically low.

When evaluating proposals in a task order competition, an agency properly may account for specific, albeit not expressly identified, matters that are logically encompassed by, or related to, the stated evaluation criteria. Immersion Consulting, LLC, B-420638, B-420638.2, June 30, 2022, 2022 CPD ¶ 171 at 7. When a protester challenges an evaluation as unfairly utilizing unstated evaluation criteria, our Office will assess whether the solicitation reasonably informed offerors of the basis for the evaluation. ERP Servs., Inc., B-419315, Feb. 24, 2021, 2021 CPD ¶ 85 at 3.

By way of background, the 21 positions at issue were all identified in the solicitation under the position type “human performance specialist (HPS)” in either the level 2 or level 3 labor category. AR, Tab 5, PWS at 9, 47. For both HPS level 2 and HPS level 3 positions, the solicitation specified minimum experience levels for “providing Human Performance services.” Id. at 9. In this regard, the solicitation described HPS services as requiring, for example, experience providing “cognitive training” to “tactical aviation populations or high-performance [Department of Defense] operational communities.” Id. For all HPS level 2 positions, the solicitation required a minimum of 5 years of experience and stated that “[p]revious management experience [was] preferred.” Id. For all HPS level 3 positions, a minimum experience level of 7 years was required, including “2+years of leadership and management experience with efforts of similar size and complexity.” Id. Concerning minimum education and certification requirements, all level 2 and level 3 positions required a “Masters or Doctoral degree in a field related to Human Performance,” and each required “[l]icense[s] and/or certification from a nationally recognized organization in a relevant [human performance] discipline[.]” Id.

As noted above, for all 21 level 2 and level 3 HPS positions, the Air Force compared T3i's proposed unburdened hourly labor rates to the labor rate range the agency established using published salary data from an “[o]rganizational [p]sychologist” labor category. AR, Tab 8, FODD at 8; AR, Tab 19, Second Decl. of Program Manager at 4.

T3i argues that although the HPS positions “have some overlap of skills/duties with an organizational psychologist,” each individual HPS position “does not meet the definition of nor the responsibilities of an organizational psychologist.” Comments at 10. As a result, it was “unreasonable and unstated criteria” for the Air Force to use a single labor category--organizational psychologist--as a basis of comparison when evaluating the realism of proposed rates for these 21 positions. Id.

In responding to this argument, the Air Force explains the analysis it used to select the “organizational psychologist” category as a compensation benchmark for the HPS positions. In this regard, the agency first notes that the 21 HPS positions were new positions for which there was no historical pricing or corresponding ERI market data. AR, Tab 13, Decl. of Program Manager at 2. Because ERI's database did not include a labor category with a direct analog to human performance specialists, the agency conducted market research into other publicly available compensation databases. Id. Specifically, the agency used the ERI “Salary Assessor” dataset, which includes salary information, job descriptions, and education requirements for various labor categories; the agency then validated that information by comparing salary data obtained from Salary.com. AR, Tab 19, Second Decl. of Program Manager at 2. The agency ultimately chose the organizational psychologist labor category as a basis for compensation comparison because it closely aligned with the duties, qualifications and compensation benchmarks for all HPS positions. Id.; AR, Tab 13, Decl. of Program Manager at 2; AR, Tab 8, FODD at 4, 8. The agency explains further that it established comparative compensation ranges to be broad enough to account for any variation in compensation expectations amongst the different HPS positions. AR, Tab 19, Second Decl. of Program Manager at 2.

Based on our review of the record, we see no basis to question the agency's judgment. The agency determined that there were no equivalent ERI labor categories to align with the HPS level 2 and HPS level 3 positions. AR, Tab 13, Decl. of Program Manager at 2. As a result, the agency used market research to analyze comparable performance requirements and salary data to arrive at a reasonable benchmark to use for comparison purposes in the price realism analysis. Id. In this regard, the agency persuasively explains that the organizational psychologist position included similar education requirements, strategic responsibilities and compensation expectations as required for all HPS positions.[7] See AR, Tab 19, Second Decl. of Program Manager at 2-3. Further, the agency notes that it intentionally set a broad salary range for these positions to account for compensation fluctuations and then compared T3i's proposed labor rates to the low “base” rate in this salary range. Id. at 2.

On this record, we find that the agency's use of the organizational psychologist labor category to evaluate T3i's HPS labor rates was logically encompassed by the stated evaluation criteria, and as noted above, was a reasonable exercise of the agency's discretion in conducting the price realism evaluation. T3i's disagreement with the agency's judgment, without more, is insufficient to establish that the evaluation was unreasonable. AKAL Sec., Inc., supra at 5.

Finally, T3i argues that, instead of using “organizational psychologist” labor rate data, the Air Force's price realism evaluation should have considered T3i's pricing narrative, which explained T3i's unique pricing approach for the HPS positions. See Protest at 13; Comments at 7-12; Supp. Comments at 7-12. As we explained above, however, even if we agreed with the protester that considering the pricing narrative would have affected the Air Force's analysis, we would still find no basis to sustain T3i's protest because the nature and extent of an agency's price realism analysis are matters within the agency's discretion. See NTT DATA Servs. Fed. Gov't., Inc., supra at 3. Moreover, the protester again fails to explain how its pricing narrative provided meaningful insight into T3i's pricing approach for these HPS positions. As noted above, T3i's pricing narrative is overly general and does not address, for example, how T3i intended to meet the solicitation requirements for each HPS position with T3i's low proposed labor rates. See generally AR, Tab 7, T3i's Pricing Narrative. As a result, we see no support for T3i's argument that its pricing narrative specified its unique approach to meeting the solicitation's requirements. Nor do we agree that the agency was obligated to consider the narrative when conducting the price realism evaluation. Accordingly, we see no basis to sustain this protest allegation.

The protest is denied.

Edda Emmanuelli Perez
General Counsel

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