ID8Spark, 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: ID8Spark, LLC

File: B-424253.2; B-424253.3; B-424253.5

Date: May 18, 2026

David B. Dixon, Esq., Meghan D. Doherty, Esq., Alexis P. Landrum, Esq., and Aleksey R. Dabbs, Esq., Pillsbury Winthop Shaw Pittman LLP, for the protester.
J. Ryan Frazee, Esq., and John. R. Prairie, Esq., Mayer Brown LLP, for Chags Health Information Technology LLC, the intervenor.
Brandon Dell'Aglio, Esq., and William Shim, Esq., Department of Health and Human Services, for the agency.
Paul N. Wengert, Esq., and Tania Calhoun, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.

DIGEST

1. Protest that agency misevaluated quotations and engaged in disparate treatment under competition for Federal Supply Schedule task order is denied where the record shows the evaluation was reasonable and consistent with the solicitation criteria and differences in evaluation treatment was the result of differences in vendors' quotations.

2. Protest challenging agency's selection of the best-suited vendor and the subsequent conduct of exchanges only with that firm is denied where the record shows the best-suited vendor determination was reasonable and consistent with the terms of the solicitation.

DECISION

ID8Spark, LLC, of Catonsville, Maryland, a small business, protests the issuance of a Federal Supply Schedule (FSS) task order to Chags Health Information Technology LLC, doing business as C-HIT, of Columbia, Maryland, also a small business, under request for quotations (RFQ) No. RFQ-CMS-2026-260007J, issued by the Department of Health and Human Services, Centers for Medicare and Medicaid Services (CMS), for commercial services to support the agency's application programming interface (API) gateway. ID8Spark argues that CMS misevaluated the quotations, improperly held discussions only with C-HIT, and made an unreasonable source selection decision.

We deny the protest.

BACKGROUND

The RFQ, issued on September 26, 2025, sought quotations from small businesses to provide support services for CMS's API gateway[1] under a hybrid firm-fixed-price/time and material task order for a base year and four option years. The RFQ provided that the competition would be conducted under the procedures of Federal Acquisition Regulation (FAR) subpart 8.405 and the FSS. Agency Report (AR), Tab 2.4, RFQ app. C, Additional Information at 2. The task order would be issued to the vendor whose quotation provided the best value based on an evaluation of quotations under four factors: corporate experience (mission focused); performance work statement (PWS) and quality assurance surveillance plan (QASP); oral presentations; and cost.[2] AR, Tab 2.14, RFQ amend. 2, attach. 5, Evaluation Criteria at 2‑12.[3] The first three factors were of equal importance; all non-cost or price factors, when combined, were more important than cost or price. AR, Tab 2.4, RFQ app. C, Additional Information at 3.

The RFQ divided the competition into two phases. In phase 1, vendors provided quotations addressing only the corporate experience factor, which CMS would evaluate and inform the vendor of the agency's determination of whether the vendor should participate in the next phase.[4] In phase 2, vendors submitted quotations addressing the remaining factors, except for the oral presentations factor which was presented live.

The corporate experience (mission focused) factor evaluation would assess how well a vendor's previous experience demonstrates performance of work “similar to that envisioned by the Government in pursuit of the intent described in this solicitation.” AR, Tab 2.14, RFQ amend. 2, attach. 5, Additional Information at 4.

The RFQ provided a statement of objectives (SOO) identifying the general scope of the task order, nine objectives that included program management, operations and management, and application rationalization for a platform alternative. The SOO also identified required key personnel, deliverables, and government-furnished equipment and information. AR, Tab 2.19, RFQ amend. 3, SOO at 2-3. Under the PWS and QASP factor, vendors had to provide a PWS to meet the CMS objectives, along with a draft QASP for CMS to use in developing its own QASP to monitor the vendor's performance. AR, Tab 2.14, RFQ amend. 2, attach. 5, Evaluation Criteria at 5. CMS would evaluate the vendor's PWS and draft QASP to assess how they met the intent of the SOO, and, specifically, “how well the PWS demonstrates understanding of the Government's needs, and the extent to which the people, processes, performance measures and tools will serve to address the needs and challenges” of performance. Id. at 6.

For the oral presentation factor, the RFQ provided that all vendors would receive the same set of “core questions” at the beginning of the presentation. The vendor was instructed to present its answers to the questions and demonstrate its approach to the agency's requirement. Id. at 6. The oral presentation evaluation would assess the “capability and suitability of the [vendor] to perform the work required by the SOO,” and consider not only the content of the vendor's answers but also “the methods used by the team to deliver those answers.” Id. at 9.

Under the cost factor, vendors were instructed to submit a basis of estimate that described the estimating methodology the vendor used to develop its price and to complete a pricing spreadsheet. The cost factor evaluation would evaluate the quoted prices for the base period, option period(s), and the six-month extension to ensure they are fair and reasonable. Id. at 11.

Although the RFQ indicated that the agency was not obligated to hold exchanges with vendors, CMS reserved the right to conduct exchanges if the contracting officer determined that doing so was necessary and in the best interest of the government. AR, Tab 2.4, RFQ app. C, Additional Information at 2. If exchanges were held, the contracting officer could limit participation “to the greatest number that will permit an efficient competition among those responses most likely to be determined best value.” Id. at 3. However, after CMS had determined that one vendor's quotation was

the best value (i.e. the apparent successful respondent), the government reserves the right to communicate with only that respondent to address any remaining issues, if necessary, and finalize a task order. These issues may include technical and/or price matters.

Id.

CMS received phase 1 quotations from 27 vendors, including ID8Spark and C-HIT. After evaluating the quotations, the agency advised all vendors except C-HIT that they should not continue to phase 2. In the communication sent to ID8Spark, CMS advised that the phase 1 evaluation under the corporate experience (mission focused) factor had resulted in a rating of some confidence. Three vendors (ID8Spark, C-HIT, and Octave[5]) submitted phase 2 quotations and participated in oral presentations. Supp AR, Tab 4.2, Award Decision Memorandum at 3.

A technical evaluation panel (TEP) prepared a narrative evaluation of each vendor's quotation under each evaluation factor. The evaluation of non-price factors assessed “[p]ositive finding[s]/observation[s],” which were individual aspects that increased confidence of successful performance, and “[n]egative findings/observation[s],” which were issues that decreased confidence. The evaluation also assigned adjectival ratings ranging from high confidence to some confidence, low confidence, or no confidence. Supp AR, Tab 4.2, Award Decision Memorandum at 6.

With respect to C-HIT's corporate experience (mission focused) factor evaluation, the evaluation identified no negative factors and nine positives. Id. Under the PWS and QASP factor, the initial evaluation identified no negative findings for C-HIT but there were aspects that would require clarification. Id. at 12. Under the oral presentation factor, C-HIT's presentation was assessed no negative findings and four positives. Id. at 10. The price evaluation found that C-HIT's initial quotation was consistent with its technical quotation, but a discrepancy in pricing for nine labor categories limited CMS's ability to evaluate its pricing, and the firm had quoted pricing for three labor categories that exceeded the firm's FSS contract pricing for the corresponding labor categories. Id. at 18.

The evaluation of ID8Spark's quotation identified multiple concerns under two evaluation factors (corporate experience (mission focused) and the PWS and QASP), the most significant of which we review below. Under the oral presentations factor, CMS evaluated the presentations by both ID8Spark and C-HIT positively and assessed them as essentially equal. After completing the evaluation of each vendor's initial phase 1 and phase 2 quotations, the contracting officer prepared a table of the adjectival ratings and total prices:

	Corporate Experience (Mission Focused)	PWS and QASP	Oral Presentation	Total Price
C-HIT	High Confidence	High Confidence	High Confidence	$33,660,332.37
ID8Spark	Some Confidence	Some Confidence	High Confidence	$19,999,699.27
Octave	Low Confidence	Some Confidence	Some Confidence	$25,865,988.92

Supp AR, Tab 4.2, Award Decision Memorandum at 5.

The memorandum then recorded the contracting officer's determination: “[b]ased on the evaluation of the price and non-price factors described in this section, the [contracting officer] determined that C-HIT was the apparent best suited offeror” and referred to the remaining narrative for supporting explanation of the supporting evaluation judgments. Id. The agency then held an initial round of exchanges with C‑HIT and asked the firm to submit a revised quotation. After evaluating the revised quotation, CMS held a second round of discussions with C-HIT and received another revised quotation. Following those exchanges, the contracting officer prepared the award decision memorandum that reviewed the evaluation findings and determined that C-HIT's quotation provided the best value to the government. The contracting officer then selected C-HIT to be issued the task order.

CMS notified the unsuccessful vendors of C-HIT's selection and provided a brief explanation of the basis for the decision to both unsuccessful vendors. This protest followed.

DISCUSSION

ID8Spark argues that CMS misevaluated both its and C-HIT's quotations and engaged in unequal treatment. ID8Spark raises multiple challenges under the corporate experience (mission focused) and the PWS and QASP evaluation factors, all of which we have reviewed and find that none provide a basis to sustain the protest. We discuss a selection of the most significant arguments below as examples. ID8Spark also argues that CMS improperly held exchanges only with C-HIT. We consider first ID8Spark's challenges to the evaluation of quotations and then to its challenges to the selection of C-HIT as the best suited vendor. For the reasons discussed below, we conclude that the evaluation of quotations was reasonable and consistent with the RFQ, and that CMS properly decided to hold exchanges with C-HIT and, after reviewing the firm's final revised quotation, to select it as the successful vendor.

Where a vendor challenges the evaluation of quotations in a competition under FAR 8.4, our Office will review the record to determine whether the agency's evaluation conclusions were reasonable and consistent with the terms of the solicitation and applicable procurement laws and regulations. Neopost USA Inc., B-404195, B‑404195.2, Jan. 19, 2011, at 4. In reviewing such a challenge, our Office will not limit our review of the agency's evaluation to the contemporaneous documentation, but instead will consider all the information provided, including the agency's protest arguments and explanations that provide a detailed rationale for a contemporaneous conclusion and simply fill in previously-unrecorded details and are credible and consistent with the contemporaneous record. Softrams, LLC; Chags Health Info. Tech., LLC, B-419927.4 et al., Feb. 7, 2022, at 7. While a procuring agency is required to have identified the significant evaluation factors and subfactors in the solicitation, it is not required to identify every aspect within a factor that could be evaluated and may include in the evaluation aspects that, although unstated, are reasonably related to or encompassed by the stated evaluation criteria. Millennium Space Sys., Inc., B-406771, Aug. 17, 2012, at 7. Further, where a protester challenges the evaluation of the quotations as reflecting disparate treatment, it must show that differences in the evaluations were not the result of differences in the vendors' approaches. That is, a protest alleging disparate treatment must show that the evaluation of the protester's quotation differed from the awardee's but the relevant approaches in their quotations were substantively indistinguishable or nearly identical. SOS Int'l, LLC, B-422323, Apr. 24, 2024, at 7.

Corporate Experience (Mission Focused) Evaluation

ID8Spark challenges the evaluation of its quotation under the corporate experience (mission focused) factor, arguing that CMS unreasonably assessed a negative finding and overlooked additional positive findings in its quotation. In addition to 7 positive findings, the agency assessed ID8Spark's quotation with 1 negative finding. AR, Tab 3.1, TEP Phase 1 Evaluation of ID8Spark at 4-9. The protester argues that the negative finding was unreasonable and that CMS also unreasonably failed to assess additional positive findings. Protest at 25-28. CMS assessed the negative finding because the agency determined that ID8Spark had not shown experience in developing, updating, and maintaining Salesforce workflow processes to support automated credentialing and authorization to APIs, which was one of the subjects that the RFQ had identified as a focus area for the corporate experience (mission centered) factor evaluation. AR, Tab 3.1, TEP Phase 1 Evaluation of ID8Spark at 9-10; Protest at 25. The protester argues that the agency improperly disregarded the information in its quotation, which identified a blanket purchase agreement (BPA) that demonstrated the necessary experience.

ID8Spark provided four corporate experience references in its phase 1 quotation, one of which is at issue here. In that regard, ID8Spark identified one reference as having been performed by ID8Spark's subcontractor, [DELETED], which was the only reference demonstrating experience in the RFQ's experience focus area of developing, updating, and maintaining Salesforce workflow processes to support automated credentialing and authorization to APIs. ID8Spark described the BPA as having been issued to [DELETED] by the Department of the Interior, Bureau of Land Management (BLM). AR, Tab 6.1, ID8Spark Phase 1 Quotation at 6. The quotation described [DELETED]'s work under the BPA as involving modernization of BLM's legacy mineral and land records system (MLRS) into a platform based on Salesforce. Id. The quotation identified the firm performing the work as [DELETED], a small business joint venture with two participants: a small business named [DELETED] and a large business, [DELETED]. Id. at 4. ID8Spark maintains that the experience of [DELETED] and [DELETED] had to be considered as the experience of [DELETED] under a regulation promulgated by the Small Business Administration (SBA), 13 C.F.R. 125.8(e). That regulation describes the requirements applicable to certain small business joint ventures that submit an offer (or quotation, as here) for a set-aside requirement and provides, in relevant part, as follows:

When evaluating the . . . experience. . . of an entity submitting an offer . . . as a joint venture established pursuant to this section, a procuring activity must consider work done and qualifications held individually by each partner to the joint venture as well as any work done by the joint venture itself previously.

Id.

CMS argues that it reviewed the information in ID8Spark's quotation but, in attempting to verify it, found that the BPA was listed in contracting databases as being issued to [DELETED], rather than to [DELETED] itself. Memorandum of Law (MOL) at 9. Specifically, CMS retrieved records regarding the BPA, which showed that it had been awarded to [DELETED], not [DELETED]. AR, Tab 7.1, USASpending Database for MLRS BPA at 1; AR, Tab 7.2, FPDS Database for MLRS BPA at 1. As a result, the evaluators determined that the MLRS experience could not be credited to [DELETED] and, in turn, could not be credited to ID8Spark, and the contracting officer agreed. MOL at 8-9; AR, Tab 3.1, TEP Phase 1 Evaluation of ID8Spark at 8-9; AR, Tab 4.1, Award Decision Memorandum at 8.

CMS argues that the evaluation correctly excluded the experience that, according to available records, was performed by [DELETED], not by [DELETED]. CMS argues that the RFQ expressly limited consideration of experience to performance by the vendor submitting the quotation (that is, ID8Spark itself) and to certain first-tier subcontractors that were small businesses, stating as follows:

[Proffered experience] must be that of the proposed prime contractor or a CTA [contractor teaming agreement] teammate; experience from subcontractors, individual employees or consultants will not be considered. However . . . where a small business prime contractor includes a proposed team of small business subcontractors and specifically identifies the first-tier subcontractor(s) in the quotation, the experience of any such subcontractors may be considered.

AR, Tab 2.14, RFQ amend. 2, attach. 5, Evaluation Criteria at 2; MOL at 9.

The agency contends that the experience reference cited by ID8Spark could not be considered as experience of ID8Spark because, contrary to the description in ID8Spark's quotation, the MLRS BPA had not been issued to [DELETED] so it did not meet the standard for consideration as part of ID8Spark's experience. Therefore, CMS argues that the assessment of a negative finding for ID8Spark's lack of experience in one of the RFQ's experience focus areas was reasonable. Id.

As noted above, the record shows that contracting database records obtained by CMS contradicted ID8Spark's claim in its quotation that the MLRS BPA had been performed by [DELETED]; instead, those records showed that the BPA had been issued to a large business, [DELETED]. Indeed, ID8Spark acknowledges in its protest that the BPA at issue was not held by [DELETED] itself, but “by [DELETED][‘s] joint venture member [DELETED] as the prime contractor,” but the firm adds that [DELETED]'s small business joint venture participant, [DELETED], was a subcontractor on the MLRS BPA. Protest at 28. As a result, ID8Spark contends that the experience of both [DELETED] and [DELETED] on the MLRS BPA was effectively the experience of [DELETED]. In turn, because [DELETED] is a first-tier small business subcontractor to ID8Spark, the firm argues that CMS was required to consider the MLRS experience when assessing ID8Spark's corporate experience. Comments & Supp. Protest at 15-16.

Our review of the record shows that ID8Spark's quotation listed the firm performing the MLRS BPA as [DELETED]. Although the protester now acknowledges that the BPA was, in fact, issued to [DELETED], and asserts that [DELETED] was a subcontractor on the BPA, the quotation does not include that fact.[6] Further, even though the quotation did identify [DELETED] as a joint venture of [DELETED] and [DELETED] that would be a subcontractor to ID8Spark, neither the RFQ nor SBA regulation 13 C.F.R. 125.8(e) required CMS to include [DELETED]'s experience when evaluating ID8Spark under the corporate experience (mission focused) factor. The information known to CMS only showed that [DELETED] had performed the MLRS BPA, and that [DELETED] was now a joint venture participant in ID8Spark's proposed subcontractor, [DELETED]. The RFQ language that permitted the corporate experience (mission focused) factor evaluation to include “the experience of any such [first-tier small business] subcontractors” did not apply because the information available to CMS showed that [DELETED] had not performed the MLRS BPA (contrary to ID8Spark's claim in its quotation).

The requirement of 13 C.F.R. 125.8(e) did not apply because the firm that had performed the MLRS BPA, [DELETED], was not “an entity submitting an offer . . . as a joint venture established pursuant to this section,” but was, instead, merely a participant in a proposed subcontractor joint venture. As a result, CMS had no obligation to treat the experience of [DELETED] as the experience of ID8Spark's small business subcontractor, [DELETED] and, in turn, of ID8Spark, under either the terms of the RFQ or the SBA regulation. Consequently, the record confirms CMS's conclusion that ID8Spark lacked experience in one of the focus areas listed in the RFQ because the experience it cited was not a contract (or BPA) that ID8Spark's subcontractor had held as the prime contractor. As a result, the assessment of a negative finding was reasonable and, on that basis, the evaluators reasonably assessed a rating of some confidence for ID8Spark under the corporate experience (mission focused) factor.[7]

PWS and QASP Factor Evaluation

ID8Spark raises multiple challenges to both its own and C-HIT's quotations under the PWS and QASP factor, arguing that CMS unreasonably assessed negative findings to ID8Spark's quotation, Protest at 28-31, while overlooking defects that should have been assessed negative findings in C-HIT's quotation. Comments & Supp. Protest at 8-10. We have reviewed the record regarding each challenge and find that none have merit. Below, as examples, we discuss the evaluation of two of the negative findings for ID8Spark's quotation and one allegedly overlooked defect in C-HIT's quotation.

As background, as noted above, one of the SOO objectives was application rationalization--platform alternative. For that objective, the SOO explained that the agency's existing API gateway faced increasing demands for application development. CMS needed the vendor to provide application rationalization[8], specifically in regard to the existing platform (identified as “Salesforce: MuleSoft Anypoint”), to analyze whether it would provide a good technical fit and a rational total cost of ownership. AR, Tab 2.19, RFQ amend. 3, SOO at 20. Accordingly, one of the agency's SOO objectives was for the vendor to “propose a platform alternative, preferably the technology suit[e]s available within CMS [content management system] AWS [Amazon Web Services] Cloud services, i.e., AWS solution components,” and for the vendor to outline a technical approach for transition to and further development of that solution while preserving the agency's business operations and minimizing downtime. Id.

Additionally, the RFQ required the vendor to include in its PWS information about its staffing, including an approach that completed onboarding of personnel within 30 days, and to provide the identities and qualifications of proposed key personnel in six positions: program manager, product manager/operations lead, API architect lead, development and operations (DevOps)/technical lead, federal healthcare program subject matter expert, and security analyst/information systems security officer. AR, Tab 2.19, RFQ amend. 3, SOO at 15, 28-30. The RFQ listed various experience and abilities that the product manager/operations lead candidate was required to have, such as an understanding of needs and issues (e.g., “needs of the business, representing the true voice of the customer, communicating with design/business teams, and aligning technical activities”), showing expertise and ability in relevant areas, and having knowledge of relevant topics. Id. at 29. Additionally, the description stated that a bachelor's degree and a relevant certification were required. Id.

With regard to the evaluation of its own quotation, ID8Spark argues that each of the four negative findings assessed to its quotation was unreasonable. ID8Spark argues that a negative finding for failing to adequately define testing activities as part of its approach to the application rationalization task applied unstated criteria; another for providing conflicting statements about whether its approach would achieve full staffing within [DELETED] or [DELETED] days was an obvious and unimportant mistake; and a third for omitting labor hour figures for six labor categories [DELETED]; and fourth for failing to provide a mitigation plan for [DELETED], which were both allegedly based on CMS's failure to consider the information in ID8Spark's quotation. Protest at 28-31; Comments & Supp. Protest at 22-24. None of them justified assessment of a negative finding, the protester contends.

As noted above, our review of these challenges considers whether the agency's evaluation conclusions were reasonable and consistent with the terms of the RFQ and applicable procurement laws and regulations. Neopost USA Inc., supra at 4. Where a protester argues that the evaluation was based on unstated criteria, we will not sustain the protest where the challenged aspects of the evaluation are reasonably related to or encompassed by stated evaluation criteria. Millennium Space Sys., Inc., supra, at 7.

CMS argues that the evaluation was reasonable and provided a well-reasoned explanation of why each aspect of ID8Spark's quotation was assessed a negative finding. MOL at 10. First, for the firm's approach to the platform alternative application rationalization task, the evaluators explained that while ID8Spark's quotation stated that its approach would include technical analysis, cost-benefit evaluation, and a recommendation of alternatives, and would ensure that any proposed alternatives supported full API lifecycle management, it identified no testing activities as part of its approach. The agency found that omitting testing as part of that task posed risks of, among other things, application failure, additional costs, and delays. Id. (quoting AR, Tab 3.2, TEP Phase 2 Evaluation of ID8Spark at 9). Second, with respect to the firm's timeline for attaining full staffing, the agency argues that in contrast to general statements in ID8Spark's quotation that it would “be 100 percent staffed by Day 30,” AR, Tab 6.2, ID8Spark Phase 2 Quotation at 11, the quotation provided a detailed timeline labeled as its “High-Level [DELETED]-Day Transition-In Plan Activities and Hiring Timelines” that had a line labeled “ONBOARDING STAFF” with entries stating “DAY [DELETED]: 50 [percent] Staffed,” followed by “DAY [DELETED]: 80 [percent] Staffed,” and “DAY [DELETED]: 100 [percent] Staffed.” Id. at 16. Both issues were reasonably assessed negative findings, CMS argues, because the quotation did not meet the RFQ requirements. MOL at 14.

Our review of the record supports CMS's evaluation of the negative findings in ID8Spark's quotation under the PWS and QASP factor. The RFQ informed vendors of the importance of avoiding disruption to the agency in performing the application rationalization effort for an alternative platform. While the evaluators acknowledged that ID8Spark's quotation discussed testing in relation to other objectives, its approach to the application rationalization alternative platform task does not. The evaluation record documents the evaluators' concerns that omitting testing for that objective, despite its inclusion for others, posed significant risks and amply supports the negative finding. Although ID8Spark argues that the evaluation reflects the application of unstated criteria because the objective does not identify testing as part of the evaluation under the application rationalization--alternative platform objective, the agency's consideration of testing (or lack of it) in a vendor's approach to the objective was encompassed within the stated criteria of assessing the vendor's approach that avoided interruption to business operations and minimized downtime. AR, Tab 2.19, RFQ amend. 3, SOO at 20. The record shows that the evaluators' concern that the absence of an approach to testing in ID8Spark's quotation was an appropriate one under the stated criteria and their resulting assessment of a negative finding on that basis was reasonable.

The second negative finding regarding the timeline for completion of onboarding personnel was likewise reasonable. ID8Spark's contention that the information in the timeline was an obvious typographical error that should have been disregarded in the evaluation in favor of other broad statements that the firm would complete personnel onboarding within 30 days is unpersuasive. Based on our review of the record, the evaluators were reasonably concerned that the specific milestones, which were in a table labeled as the firm's transition-in plan activities and hiring timelines, were the accurate statement of the firm's plan. Rather than a typographical error as ID8Spark claims, the quotation makes three consistent statements about the progress and timing of the onboarding effort being completed over [DELETED] days, not 30. As we have often noted, it is a vendor's responsibility to submit a well-written quotation; otherwise, it must bear the risk that the quotation will be evaluated unfavorably. NetCentrics Corp., B‑421172.2, B-421172.3, Oct. 23, 2023 at 5. ID8Spark fails to show that the evaluation of its quotation under the PWS and QASP factor was unreasonable or resulted from the application of unstated evaluation criteria, so we deny the protest of that aspect of the evaluation.

ID8Spark also challenges the evaluation of C-HIT's quotation, and argues that C-HIT misrepresented the qualifications of at least one of the firm's proposed key personnel candidates, while CMS overlooked that the candidate was allegedly unqualified. Specifically, the protester contends that C-HIT proposed a candidate for the key position of product manager/operations lead who lacked 8 years of experience. Comments & Supp. Protest at 9. ID8Spark argues that C-HIT misrepresented that the candidate had 8 years of experience, and that CMS failed to review the candidate's résumé that was in the quotation, which would have revealed the candidate was unqualified, and instead included in the list of key personnel qualifications to support a positive finding for C-HIT a statement that its candidate “offers 8 years of experience as an accomplished [p]roduct [m]anager and [o]perations [l]ead.” Id. at 10.

CMS argues that the evaluation of a positive for C-HIT based on the “exceptional” qualifications of the full slate of key personnel C-HIT offered was reasonable. MOL at 5. The agency contends that the information in C-HIT's quotation does not undermine the firm's claim that its candidate had 8 years of experience. The agency also argues that ID8Spark's argument is based not on a flaw in the evaluation but on a résumé posted online on a social media site. Supp. MOL at 15. The evaluators did not review social media résumé postings, the agency argues, and in any case an online résumé could reasonably have described the candidate's experience differently. Id. In support of the agency's position, C-HIT explains that its quotation did not state that the candidate had (nor was there a requirement to have) 8 years experience exclusively as a product manager/operations lead; rather, the quotation states that the candidate had 8 years of work experience generally, and was also an accomplished product manager/operations lead. Intervenor Supp. Comments at 17 (quoting AR, Tab 5.1, C-HIT Phase 2 Quotation at 56, 70). C-HIT also argues that experience relevant to the candidate's qualifications included work under other job titles, and was not limited to the period when the candidate had the precise job title of product manager/operations lead.

Our review of the record shows that the agency's evaluation of C-HIT's key personnel was reasonable and that C-HIT did not misrepresent the experience of its product manager/operations lead candidate. With respect to the assessment of a positive finding for the qualifications of C-HIT's key personnel, the record indicates that the evaluation of a positive finding was based on the combined experience and expertise of all six key personnel. The evaluators then noted the experience in each of the key positions, which included the product manager/operations lead candidate's 8 years of experience and their narrative justified the assessment of a positive finding on the depth of experience of the entire key personnel team in areas relevant to the agency's requirements. AR, Tab 3.4, C-HIT TEP Phase 2 Evaluation of C-HIT at 9-10.[9]

The record also provides no basis to consider C-HIT's quotation to have misrepresented the candidate's experience. The candidate's résumé provided a detailed narrative of the basis for the candidate's expertise, and listed the positions the candidate had held over more than 8 years, with the duties of each. AR, Tab 5.1, C-HIT Phase 2 Quotation at 70. In short, the quotation and the agency's evaluation of C-HIT's key personnel provide no basis to question the accuracy of either. The information in the candidate's apparent online résumé, which was evidently posted for purposes unrelated to the candidate's experience for the product manager/operations lead position, does not provide a basis to question the accuracy of the information in the quotation evaluated by CMS. Accordingly, we also deny ID8Spark's challenges to the evaluation of C-HIT's quotation.

Best-Suited Offeror Determination

ID8Spark raises a range of arguments to contend that CMS improperly conducted two rounds of exchanges with C-HIT in order to allow the firm to revise its quotation. ID8Spark argues that C-HIT's quotation was unacceptable and should have been rejected, or the agency was required to conduct exchanges with ID8Spark also. Protest at 35; Comments & Supp. Protest at 3-7; Second Supp. Protest at 3-17. The protester contends that C-HIT's quotation included aspects that rendered it unacceptable, among which were labor rates that exceeded the firm's FSS rates, and stated assumptions that were inconsistent with the RFQ, all of which precluded CMS from determining the quotation was the best value. Further, ID8Spark argues that CMS failed to document the basis for selecting C-HIT's quotation to conduct exchanges. Id.

CMS counters that it properly evaluated the quotations and that the contracting officer made a reasonable determination that C-HIT's quotation was the most suitable, and therefore, was the best value. Supp. MOL at 5-6. Based on that determination, CMS argues that the exchanges the agency conducted with C-HIT were both proper and consistent with the RFQ. MOL at 24; Supp. MOL at 9-10. With respect to the assumptions in C-HIT's quotation, the agency explains that the contracting officer's review concluded that each of the assumptions did not contradict the RFQ or reflect a lack of understanding and, instead, arose from matters that had not been addressed in the RFQ and therefore could be corrected during exchanges.[10] Supp. MOL at 7. CMS also contends that its review determined that the discrepancies in C-HIT's labor rates reflected very minor differences caused by rounding in several instances, and in others either a need for clarity about which of C-HIT's FSS labor categories was being used or a potential error in transcribing the rates, all of which the agency concluded could be addressed through exchanges. Id. at 8.

We have viewed the selection of a best-suited vendor as being, in effect, a technique to establish a competitive range of one vendor. Under that construction, our review has recognized that a contracting agency's evaluation of proposals and the establishment of a competitive range are matters within the agency's discretion. Therefore, our Office's review of challenges to both the evaluation and that competitive range determination examines the evaluation and determination to ensure that they were reasonable and consistent with the solicitation's stated evaluation criteria and with procurement statutes and regulations. Alliant Health Sols., Inc., B-423598, B-423598.2, Sept. 12, 2025, at 24. Where an agency has reasonably and fairly evaluated vendors' quotations, the agency's decision to conduct exchanges with only the “best-suited” vendor does not amount to unfair and inequitable treatment of vendors. S2 Analytical Sols., LLC, B-422281.3, Dec. 20, 2024, at 6 (under FAR subpart 8.4, the process of selecting a best suited vendor and subsequently holding exchanges or discussions with only that vendor is a permissible solicitation term).

CMS argues that the contracting officer's award decision memorandum, which documented the final source selection, also adequately documents a reasonable judgment that C-HIT's quotation was the best suited vendor for purposes of holding exchanges only with it as permitted by the RFQ. Supp. MOL at 9-10. The agency noted that C-HIT had received the highest ratings under each of the non-price factors, and the record documents the contracting officer's judgment that C-HIT was best suited for award. Id.

Based on our review of the record, the contracting officer's judgment that the evaluation of C-HIT's quotation made it the best suited vendor was reasonable. The record shows that the contracting officer recognized the evaluation of C-HIT's initial quotation reflected high confidence under all non-price factors and identified multiple positive findings and no negative findings, in contrast to the evaluation of ID8Spark's quotation. As discussed above, the record shows CMS's evaluation was reasonable. Supp AR, Tab 4.2, Award Decision Memorandum at 6-17. In areas where CMS identified issues that could be addressed through exchanges, the agency reasonably concluded that the issues did not amount to an unacceptable approach, and that exchanges could therefore resolve each of the issues. In contrast, the evaluation identified multiple negative findings for ID8Spark's quotation, including, as discussed above, a lack of experience in a critical area, a failure to address testing in the firm's approach to the application rationalization--platform alternative objective, and a timeline for onboarding that significantly exceeded the requirement, among others. Id. at 7, 14.

The record also documents the contracting officer's reasonable consideration of both vendors' initial quotation pricing, which recognized that C‑HIT's was significantly higher than ID8Spark's, and determined that paying C‑HIT's price premium was justified by the technical advantages of its quotation over ID8Spark's.[11] Supp AR, Tab 4.2, Award Decision Memorandum at 28. In particular, the contracting officer explained that the negative findings in the evaluation of ID8Spark's quotation represented risks that outweighed the price difference, while C-HIT's evaluation gave it a clear technical advantage. Id. at 27-28. The contracting officer's award decision memorandum thus reflects a reasonable judgment that the superiority of C-HIT's initial quotation justified its higher price, and therefore the firm was the best suited vendor and, ultimately, its final revised quotation provided the best value. The record shows that the contracting officer's judgments were adequately documented in the record, and the supporting rationale is reasonable and consistent with the RFQ criteria. Accordingly, we deny this allegation.

The protest is denied.
Edda Emmanuelli Perez

General Counsel

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