The Cameron Bell Corporation d/b/a Gov Solutions Group

DOCUMENT FOR PUBLIC RELEASE

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

Decision

Matter of: The Cameron Bell Corporation d/b/a Gov Solutions Group

File: B-423841

Date: December 19, 2025

Michael A. Killham, Esq., Law Office of Michael A. Killham, for the protester.
William A. Shook, Esq., The Law Offices of William A. Shook PLLC, for Red River Resources, LLC, the intervenor.
Kimberly Foxx, Esq., and Karen Debolt, Esq., Department of the Navy, for the agency.
Suresh S. Boodram, Esq., and Evan D. Wesser, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Protest challenging the evaluation of the protester's technical proposal is denied where the agency's evaluation was reasonable and consistent with the terms of the solicitation.

DECISION

The Cameron Bell Corporation d/b/a Gov Solutions Group (GovSG), a small business of Charleston, South Carolina, protests the issuance of a task order to Red River Resources, LLC d/b/a NavAide (NavAide), a small business of San Diego, California, under fair opportunity proposal request (FOPR) No. N0003925R3003, issued by the Department of the Navy, Naval Information Warfare Systems Command (NAVWAR), for professional support services. The protester contends that the agency's evaluation of the protester's proposal was arbitrary, unsupported by the evidence, and inconsistent with the FOPR's evaluation criteria.

We deny the protest.

BACKGROUND

Using the procedures of Federal Acquisition Regulation section 16.505, the agency issued the FOPR, which was subsequently twice amended, on January 8, 2025, under the Naval Sea System Command Seaport NxG Multiple Award Contract. Agency Report (AR), Exh. 2, FOPR at 4, 70.[1] The FOPR, which was set aside for small businesses, sought planning services for all major and minor Navy Enterprise Resource Planning (N-ERP) system upgrades, including the NAVWAR Enterprise's transition to a Systems, Applications, and Products in Data Processing (SAP) Business Suite 4 for SAP High-Performance Analytic Appliance (SAP S/4HANA) environment.[2] Id. at 3; AR; Exh. 1, Performance Work Statement (PWS) at 13-14. The contractor will be responsible for supporting the following business functions within the N-ERP environment: (a) master data management; (b) financial management (including (1) financial accounting; (2) revenue and cost controlling; (3) asset accounting; and (4) public sector management)); (c) program management (including (1) multi-project integration; (2) scheduling; (3) resource assignment; (4) planning and budgeting by task; and (5) project systems configuration/execution); (d) workforce management (including (1) organizational structure management; (2) personnel administration; (3) personnel development; (4) personnel time management; and (5) training and event management); (e) production planning; (f) materials management (including (1) procurement; (2) sales and distribution, (3) inventory and warehouse management; (4) environment, health, and safety; and (5) work flow management); and (g) plant maintenance (including (1) plant maintenance; (2) quality management; and (3) environment, health, and safety). AR, Exh. 1, PWS at 5-6.

The FOPR contemplated the issuance of a task order with cost and cost-plus-fixed-fee line items, with a 1-year base period, four 1-year option periods, and one 6-month option period. FOPR at 7, 9. Award was to be made on a best-value tradeoff basis using a three-phased evaluation process. Id. at 70.

In the first phase, proposals would be evaluated based on two gate criteria: facility clearance level; and organizational experience. Under these gate criteria, proposals would be evaluated on an “acceptable” or “unacceptable” basis. Id. at 71. In the second phase, proposals would be evaluated on the basis of two technical factors, listed in descending order of importance: technical; and management. Id. at 70, 72. The agency was to evaluate proposals under each factor by evaluating for positive findings, negative findings, and deficiencies. Id. at 70, 74. The FOPR defined each type of finding accordingly:

Rating	Definition
Positive Finding	Findings in the evaluation that have merit and/or provide a benefit to the Government; and/or favorably affect the demonstrated understanding of the requirements, adequacy of approach, or associated risk to performance.
Negative Finding	Findings in the evaluation unfavorably affected the demonstrated understanding of the requirements, adequacy of approach, or associated risk to performance.
Deficiency	Findings in the evaluation that are materially nonresponsive, regurgitate the work statement/requirements, lack understanding of the requirements, take exception to requirements, or provide an unacceptable level of risk to performance.

Id. at 74.

After assessing each factor with findings and deficiencies, the agency was to assign a level of risk for each factor using one of the following risk ratings: low; moderate; high; or unacceptable. Id. at 73, 75. Relevant here, low and moderate risk were defined as:

Rating	Definition
Low Risk	Proposal may contain negative findings, which have little to no potential to cause disruption of schedule, increased cost, or degradation of performance. Normal contractor effort and normal Government monitoring will likely be able to overcome any difficulties.
Moderate Risk	Proposal contains negative findings, which may cause disruption of schedule, increased cost, or degradation of performance. Special contractor emphasis and close Government monitoring will likely be able to overcome difficulties.

Id. at 75.

After the second phase was completed, the agency would determine the highest technically rated offeror (HTRO). Id. at 70. In the third phase, the agency would conduct a cost and price analysis of the HTRO's proposal to determine whether the HTRO's proposed costs were realistic and fair and reasonable. Id. The FOPR explicitly stated that “the Government intends to limit the breadth of the cost analysis and cost realism analysis only to the HTRO.” Id. at 72.

As relevant to this protest, all offerors found to be acceptable under phase one were invited to participate under phase two. Id. at 63. For phase two, as to the technical factor the agency requested offerors to submit responses to two sample scenarios. Id. at 64‑65. The FOPR directed offerors to provide their proposed technical approach to each scenario as follows:

[I]dentify opportunities and risk to the [g]overnment . . . [f]or each of the scenarios below, Offeror shall identify their proposed technical approach including quality management processes to be utilized to ensure cost, quality, and schedule requirements for work to be performed in support of the PWS. For each of the scenarios Offerors should cite two examples of relevant and recent corporate experience to demonstrate how the insight needed to solve the scenario was gained and how it would contribute to task order success.

AR, Exh. 3, Sample Scenarios at 3.

The first sample scenario question was as follows:

During the period of performance of this task order the Offeror will be tasked to plan NAVWAR's transition into the N-ERP SAP S4 environment and represent NAVWAR in technical and management working groups. Offerors shall propose a relevant and realistic plan for managing a broad business process transformation effort within an SAP ERP environment. Provide a specific example of successfully translating complex business processes into a simplified communications product for broad audience and an explanation of how that product facilitated effective business transformation. Describe the proposed approach to managing the organizational change required to realize the transformation, and the plan to codify the new business processes. Finally, describe the considerations for effectively institutionalizing the newly transformed business, and a plan to address such considerations.

Id.

The FOPR's evaluation criteria for the technical factor provided that each scenario response would be evaluated on the basis of three considerations of whether the proposed approach: (a) reflects a clear and thorough understanding and knowledge of the requirements of the PWS; (b) identifies specific processes, systems, tools and best practices for successful task order performance; and (c) demonstrates the ability to develop and implement innovative approaches and solutions under time constraints. FOPR at 72. Additionally, the agency stated that it would perform a comparative analysis between proposals and that the resulting comparative analysis would be used to determine the HTRO. Id. at 70.

On April 2, the agency received four proposals by the FOPR's phase two closing date, including from the protester and the awardee. AR, Exh. 6, Task Order Selection Official Decision Document (TOSODD) at 3. After completing its evaluation, the agency rated the protester's second phase proposal as follows:

Offeror	Factor 1: Technical Approach (Sample Scenarios)	Factor 2: Management Approach	Risk
GovSG	3 Positive/ 3 Negative/ 0 Deficiencies	1 Positive/ 0 Negative/ 0 Deficiencies	Factor 1: Moderate Factor 2: Low

Id. at 4.

Relevant to the issues presented in this protest, the evaluation team's first negative finding under factor 1 was that the protester's two examples of recent corporate experience were both limited in scope and therefore were of limited relevance to the tasks to be completed under the PWS. AR, Exh. 5, TET Report at 10. The agency's second negative finding was that the protester's response “did not adequately address translating complex business processes into a simplified communications product.” Id. at 9. The agency's final negative finding was that the protester did not adequately “address a plan to ‘codify new business processes' and just references the use of ‘out of the box' offerings of S/4HANA.” Id. at 9-10. After completing its technical evaluation, the agency found NavAid to be the HTRO. AR, Exh. 6, TOSODD at 8. In phase three, the agency found the awardee's proposed costs to be realistic, fair, and reasonable. Id. at 7.

On August 12, 2025, the agency issued the task order to NavAide and notified GovSG of the award. AR, Exh. 7, Task Order Award at 2; Exh. 8, Debriefing Letter at 2. On August 20 and after its receipt of a debriefing, the protester filed this protest with our Office.[3]

DISCUSSION

GovSG challenges two of the agency's assessed negative findings with respect to the protester's technical proposal. [4] First, the protester asserts that the agency's assessment of a negative finding with respect to the limited nature of the protester's prior corporate experience references was unreasonable and contrary to the evaluation criteria. Comments at 4-7. Second, the protester challenges the agency's negative finding that the protester failed to demonstrate a sufficient approach to translating complex business processes into a simplified communications product. Id. at 8. For the reasons that follow, we find no basis to sustain the protest.[5]

Corporate Experience Evaluation

GovSG argues that the agency improperly evaluated the relevance of the protester's two corporate experience references as being dissimilar in scope as compared to the FOPR's requirements. Specifically, the protester contends that its corporate experience references were not limited in scope and that the agency's evaluation was based, in part, on unstated evaluation criteria. Id. at 4-7. The agency maintains that its evaluation of the protester's corporate experience references was reasonable and in accordance with the terms of the FOPR, and that the protester's allegations merely disagree with the agency's evaluation. MOL at 8-13. As addressed below, we find no basis on which to sustain the protest.[6]

In reviewing a protest challenging an agency's evaluation, our Office will not reevaluate proposals, nor substitute our judgment for that of the agency, as the evaluation of proposals is a matter within the agency's discretion. BES Fed. Sols. JV, LLC, B‑420550, B-420550.4, May 11, 2022, 2022 CPD ¶ 116 at 4. Rather, we will review the record only to determine whether the agency's evaluation was reasonable and consistent with the stated evaluation criteria and with applicable procurement statutes and regulations. Id. A protester's disagreement with reasonable evaluation judgments does not provide a basis to sustain its protest. Id.

Relevant here, we have repeatedly recognized that where, as here, a solicitation does not expressly define scope, magnitude, or complexity, agencies are afforded great discretion to determine the relevance of an offeror's corporate experience or past performance. See, e.g., CW Gov't Travel, Inc., B-419193.4 et al., Apr. 15, 2021, 2021 CPD ¶ 188 at 8; Erickson Helicopters, Inc., B-418981, Oct. 22, 2020, 2020 CPD ¶ 351 at 8. Our Office will not question the agency's judgment with respect to the relevance and scope of such experience or past performance unless it is unreasonable or inconsistent with the terms of the solicitation or applicable procurement law or regulation. Commissioning Solutions Global, LLC, B-401553, Oct. 6, 2009, 2009 CPD ¶ 210 at 4. Moreover, an offeror bears the burden of submitting an adequately written proposal that contains all the information required under a solicitation. RIVA Sols., Inc., B-418408, Mar. 31, 2020, 2020 CPD ¶ 133 at 4. Where a proposal omits, inadequately addresses, or fails to clearly convey required information, the offeror runs the risk of an adverse agency evaluation. Adino Inc., B-412144, Dec. 24, 2015, 2016 CPD ¶ 7 at 6.

As addressed above and relevant to the issues presented in the protest, in phase two, offerors were required to provide their proposed technical approach to two sample scenarios, which were both representative of the efforts to be performed under the task order and relevant to the PWS. AR, Exh. 3, Sample Scenarios at 3. Offerors were instructed to “identify their proposed technical approach including quality management processes to be utilized to ensure cost, quality, and schedule requirements for work to be performed in support of the PWS.” Id. Offerors were to submit two examples of “relevant and recent corporate experience to demonstrate how the insight needed to solve the scenario was gained and how it would contribute to task order success.” Id. As noted above, the agency evaluated each offeror's proposed technical approach based on three considerations as to whether the proposed approach: (a) reflects a clear and thorough understanding and knowledge of the requirements of the PWS; (b) identifies specific processes, systems, tools and best practices for successful task order performance; and (c) demonstrates the ability to develop and implement innovative approaches and solutions under time constraints. FOPR at 72.

Scenario 1 provided that the contractor “will be tasked to plan NAVWAR's transition into the N-ERP SAP S4 environment and represent NAVWAR in technical and management working groups,” and instructed offerors to “propose a relevant and realistic plan for managing a broad business process transformation effort within the SAP ERP environment.” AR, Exh. 3, Sample Scenarios at 3. Offerors were further directed to (1) provide a specific example of successfully translating complex business processes into a simplified communications product for a broad audience and an explanation of how that product facilitated effective business transformation, (2) describe the proposed approach to managing the organizational change required to realize the transformation, and the plan to codify the new business processes, and (3) describe the considerations for effectively institutionalizing the newly transformed business, and a plan to address such considerations. Id.

GovSG submitted two corporate experience references relating to scenario 1. The protester's first corporate experience reference related to its experience implementing the Department of Treasury's G-Invoicing system. AR, Exh. 4, GovSG Proposal at 2. The protester's second reference related to its experience with the Naval Sea Systems Command's (NAVSEA) Navy Maritime Maintenance Enterprise System – Financial System (NFS). Id. Based on its review, the agency determined that both of the protester's corporate experiences were limited in scope and accordingly assigned the protester's proposal a negative finding. AR, Exh. 5, TET Report at 8.

As to the first reference, the evaluators recognized that the G-Invoicing Treasury hub required process changes within an ERP environment but noted that the changes were related only to a single business segment, as compared to NAVWAR's required transition that will include a greater number of business segments. Id. at 10; AR, Exh. 11, Decl. of TET Chair at 4 (explaining that the reference was only relevant to the reimbursable work order business segment, but did not address other covered business processes such as workforce management, inventory and material management, and project systems). As to the second reference, the evaluators noted that the NAVSEA NFS was a specific solution for NAVSEA shipyard financial requirements, and thus was not relevant to NAVWAR's needs. AR, Exh. 5, TET Report at 10; Exh. 11, Decl. of TET Chair at 3-4 (explaining that the proposal did not adequately explain “what exactly NAVSEA's ‘COST' solution encompassed other than merely a shipyard financial requirements solution,” and similarly noting that the reference only pertained to transitioning of limited financial operations and did not reflect a broader business process transformation effort covering the larger number of business segments contemplated by the PWS).

In challenging the evaluation of the protester's corporate experience references, the protester contests the agency's determination that the references were only minimally relevant to NAVWAR's requirements in terms of scope. GovSG argues that its G-Invoicing and NFS references were each a part of greater initiatives currently ongoing within the Department of the Treasury and Department of the Navy, respectively. Comments at 4-7. The protester asserts that the agency was no doubt aware of these ongoing initiatives and, therefore, the agency's assessment that both of the references were limited in scope or inapplicable to broad transformational change is unreasonable. Id.

The agency responds that its evaluation was reasonable and in accordance with the FOPR's stated evaluation criteria. The agency maintains that, as part of its relevance determination, the agency reasonably found that, based on the information included in the protester's proposal, neither of the protester's corporate experience references demonstrated broad business process transformations similar to NAVWAR's requirements and as required by scenario 1. MOL at 8-11. Therefore, the Navy contends that the protester's arguments merely express the protester's disagreement with the agency' s findings and, therefore, are insufficient to establish a viable basis of protest. We find no basis to question the agency's evaluation of the protester's G-Invoicing or NFS corporate experience references.

Scenario 1 required offerors to submit a plan for “managing a broad business process transformation effort.” AR, Exh. 3, Sample Scenarios at 3 (emphasis added). In this regard, the PWS further identified a broad range of business processes beyond just financial systems that the contractor will need to assist in transitioning to the new ERP environment. AR, Exh. 1, PWS at 5. Regarding the protester's G-Invoicing corporate experience, the agency found the experience to be limited in scope because the protester's G-Invoicing work was restricted to a single financial business segment. AR, Exh. 5, TET Report at 10. More specifically, the agency recognized that the protester's experience did not include other business segments listed within the PWS including workforce management, inventory, and material management. AR, Exh. 11, Decl. of TET Chair at 3.

Similarly, the protester's NFS corporate experience states that GovSG “assessed NAVSEA shipyard financial requirements, migrated data from Navy ‘COST' (legacy financial system) to SAP S4HANA, and successfully tested the NFS S/4HANA solution.” AR, Exh. 4, GovSG Proposal at 2. Under its relevance analysis, the agency found the experience to be limited in scope because the agency could not identify what the agency's “COST” solution encompassed beyond shipyard financial requirements solution, which again only demonstrated experience with the financial business segment but did not reflect the type of broader transformation across multiple business segments contemplated by scenario 1 and the PWS. AR, Exh. 11, Decl. of TET Chair at 4. Based on the limited description of the scope of the prior efforts contained in GovSG's proposal and the requirements of scenario 1 and the PWS, we find no basis to object to the agency's determination that the cited references demonstrated only limited relevance in terms of scope where the references appear to be limited to only a single business segment.

To the extent that the protester argues the agency should have considered information about its prior experience references that was not included in GovSG's proposal, we find no merit to such arguments. In this regard, the protester, for the first time in its comments, cites and relies on information not previously included in its proposal as information that the agency “is no doubt aware” of or is “known by the government's NAVWAR team.” See, e.g., Comments at 4-7 (describing additional details about the scope of and the protester's efforts relating to G-Invoicing and NAVSEA NFS). As addressed above, it is offeror's responsibility to prepare an adequately written proposal for the agency's consideration. RIVA Sols., Inc., supra. To the extent that GovSG's protest submissions attempt to more clearly articulate the virtues of its experience, our review is limited to the proposal, as submitted, as contracting agencies are not responsible for evaluating information that is not included in a proposal. Blue Origin Federation, LLC; Dynetics, Inc.-A Leidos Co., B-419783 et al., July 30, 2021, 2021 CPD ¶ 265 at 37 n.20. This is especially true where the FOPR directed offerors to “assume that the Government has no prior knowledge of their facilities or experience and [that the agency] will base its evaluation on the information provided in the Offeror's proposal,” FOPR at 60, and specifically required offerors to submit a proposal with “sufficient detail to substantiate the validity of stated claims,” id. The burden thus rested with GovSG to ensure that it properly explained all aspects and breadth of its proposal, and the protester's failure to do so does not render the agency's judgment unreasonable.

Complex Business Plan Translation

The protester also challenges the agency's negative finding under scenario 1 that the protester failed to adequately address translating complex business processes into a simplified communications product. Specifically, the protester asserts that its proposal to implement communication applications and a dashboard was sufficient to satisfy the agency's requirement for a communications product. Comments at 8. Therefore, the protester should have been assigned a positive finding and the agency's assignment of a negative finding was improper. Id.

The agency maintains that its evaluation was reasonable and consistent with the FOPR's evaluation criteria. The agency argues that it reasonably found that while the protester's proposed tools are platforms for communications and can provide for a visualization of data that could be used in helping to manage organizational change and codification of new business processes, they are not, in-and-of-themselves, the substance of what would need to be communicated to end users to effectuate such transformation and codification. See, e.g., AR, Exh. 11, Decl. of TET Chair at 4. In short, while these tools could facilitate communication with end users, the agency found that the proposal was missing critical details including regarding what would be communicated and how end users would be engaged and included in testing. Id. at 5.

As explained above, in reviewing a protest challenging an agency's evaluation, our Office will not reevaluate proposals, nor substitute our judgment for that of the agency, as the evaluation of proposals is a matter within the agency's discretion. BES Fed. Sols. JV, LLC, supra at 4. Here, the sample scenario required offerors to “[p]rovide a specific example of successfully translating complex business processes into a simplified communications product for broad audience and an explanation of how that product facilitated effective business transformation.” AR, Exh. 3, Sample Scenarios at 3. In its proposal, the protester cited its development of a PowerBI dashboard to “simplify, via visualizations, N-ERP metrics specific to NAVWAR.” AR, Exh. 4, GovSG Proposal at 4. The protester's proposal goes on to describe the metrics of the dashboard and describes the advantages of the dashboard as allowing the protester to “assess resource allocation, target improvement initiatives and escalate recurring trends in the data.” Id.

We do not find the protester's argument to be convincing. Here, the protester's primary argument is that its PowerBI dashboard met the FOPR's requirement for a communications product and the protester's proposal, therefore, should have been assigned a positive finding in this regard. To support its argument, the protester cites to the definition of a “dashboard” from the website of the application the protester uses to build its project dashboards to argue that the way a dashboard “display[s] various types of visual data in one place,” constitutes a communications product. Comments at 8. The protester's argument, however, fails to address the main reason as to why the agency assigned the protester a negative finding.

In its evaluation of the protester's proposal, the agency acknowledges the protester's dashboard “provides visualization to identify trends, patterns and common issues.” AR, Exh. 5, TET Report at 9. Notwithstanding this point, the agency also stated that dashboards “do not describe facilitating a business transformation but are rather a measure of current performance.” Id. In this regard, the agency submits that actual communications products, as opposed to the tools utilized for communicating, include the necessary communications to effectuate business transformation such as a communication plan, to-be-process flows, or training materials. Id.

In this regard, the agency points to the differences between the two technical scenarios to highlight why its interpretation is reasonable. In this regard, scenario 2 – NAVWAR Business – Mission Analytics (How do we know we are winning?), was focused on the development and implementation of “various data integration and analytics,” including asking based on prior experience how “analytics would be used by the workforce/ command leadership and how results would be briefed to decision makers.” AR, Exh. 3, Sample Scenarios at 3. For this factor, tools such as dashboards would be highly relevant. In contrast, scenario 1 was focused on “a relevant and realistic plan for managing a broad business process transformation effort,” and sought an example of “successfully translating complex business processes into a simplified communications product for broad audience.” Id. We agree with the agency that while scenario 2 reasonably sought information about the tools used for collecting data and communicating such analytics, scenario 1 was more focused on communications strategy and content, which the protester's proposal failed to adequately describe. On this record, we find no basis to object to the agency's reasonable evaluation.

The protest is denied.

Edda Emmanuelli Perez
General Counsel

---