Core Government Services Corporation

DOCUMENT FOR PUBLIC RELEASE
The decision issued on the date below was subject to a GAO Protective Order. No party requested redactions; we are therefore releasing the decision in its entirety.

Decision

Matter of: Core Government Services Corporation

File: B-424491

Date: August 3, 2026

Edward J. Tolchin, Esq., and Pavan Mehrotra, Esq., Offit Kurman, P.A., for the protester.
Damien C. Specht, Esq., James A. Tucker, Esq., and Thomas Lee, Esq., Morrison & Foerster LLP, for Encore JV1, LLC, the intervenor.
Jason A.M. Fragoso, Esq., and Lauren Prater, Esq., Department of Veterans Affairs, 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 protester's experience as providing low confidence of successful performance is denied where the record shows the agency's evaluation was reasonable and consistent with solicitation criteria.

2. Protest that agency improperly eliminated protester's proposal from consideration for award after evaluating the firm's experience is denied where the solicitation expressly provided that the agency could eliminate any proposal that was rated low confidence under any non-price evaluation factor.

DECISION

Core Government Services Corporation, of Leesburg, Virginia, a small business, protests the award of a contract to Encore JV1, LLC, of Chantilly, Virginia, also a small business, under request for proposals (RFP) No. 36C10X25R0032, issued by the Department of Veterans Affairs (VA) for commercial call center staffing services. Core argues that its proposal was misevaluated under the experience factor and improperly excluded from further evaluation or consideration for award.

We deny the protest.

BACKGROUND

The RFP, issued on August 27, 2025, sought proposals from service-disabled veteran-owned small businesses to provide services under a hybrid contract to include firm-fixed-price and labor hour deliverables for a base year and 4 option years. Agency Report (AR), Tab 4, RFP amend. 2 at 117, 156. The services implement the Veterans Experience Office Contact Center (VEOCC), a hotline that handles roughly 1.6 million calls annually to provide a “critical resource for our nation's Veterans, their families, caregivers, and survivors seeking assistance with VA benefits, healthcare appointments, crisis support, and other essential Veteran[-]related services.” Contracting Officer's Statement (COS) at 2.

A contract would be awarded to the firm whose proposal offered the best value to the VA under three factors, listed in descending order of importance: experience, past performance, and price. AR, Tab 8, Experience Evaluation Report for Core. As relevant here, under the experience factor, the evaluation would assess the extent to which the offeror's prior experience indicates a likelihood of successful performance under the contract. The evaluation under this factor would pay “particular attention” to assessing the offeror's experience under four subfactors: relevance, role and scope of work, complexity and operational scale, and recency and duration. Id. at 192.

Under the experience factor, the VA would assess a rating characterizing the level of confidence shown by the offeror's experience: high confidence, some confidence, low confidence, and no confidence. Id. at 84, 193. A rating of “some confidence” would apply where the offeror's experience showed it had “performed efforts similar in some aspects (size, scope, and complexity), but with some gaps or differences that create[d] moderate uncertainty.” Id. In contrast, a “low confidence” rating would apply where the offeror had “minimal or no experience similar in size, scope, and complexity, or the experience provided [was] not clearly aligned with the requirement.” Id.

Offerors were instructed to provide information about three references that demonstrated their experience (or that of a subcontractor) performing comparable work. Id. at 189. The RFP also stated (with the first paragraph in bold type):

For proposals which receive a “Low Confidence” or “No Confidence” Government confidence rating in any given Non-Price factor, the Government reserves the right to cease further evaluation and remove the Offeror from consideration for award.

In the event that no proposals receive a rating of “Some Confidence” or higher on all Non-Price factor(s), the Government reserves the right to request revised proposals and/or enter discussions with Offeror[s] who received “Some Confidence” or higher on at least one Non-Price factor.

Id. at 194-195 (emphasis omitted).

The VA received proposals from 36 offerors, and proceeded to evaluate the eligible proposals, starting with the experience factor. COS at 5. Core submitted information for three experience examples in its proposal. The first had been performed by Core itself, and the other two had been performed by the firm listed in Core's proposal as its principal subcontractor. AR, Tab 6, Core Proposal, vol. I, at 3, 5, 7.

Overall, the evaluators concluded that, although Core's experience showed the ability to manage a contact center of the size, complexity, and sensitivity required by the VEOCC, none of Core's experience references were comparable to the RFP requirements. In particular, the VA noted that the firm's experience included a lower number of annual calls and staffing levels, and that there were other differences between the firm's experience and the VEOCC requirement with regard to the levels of sensitivity, the specific technology platforms used to handle calls, and the measures those contracts applied to track the firm's performance. Id. at 6. The evaluators concluded that despite Core's experience meeting the requirement to be recent and of sufficient duration, “overall gaps in scale, staffing, technology alignment, population served, and performance oversight” resulted in low confidence in Core's ability to perform the requirements and, therefore, rated the firm low confidence under the experience factor. AR, Tab 8, Experience Evaluation Report for Core at 6.

Based on Core's experience factor rating, the VA did not evaluate the proposal further. On April 30, 2026, the VA notified Core that its proposal had been rejected. In a debriefing, the agency explained that the rejection was based on Core's low confidence adjectival rating under the experience factor, and that the protester's proposal had not been evaluated further. This protest followed.

DISCUSSION

Core challenges the evaluation of its experience, arguing that its three experience examples should have been combined for purposes of determining whether the experience was similar to that required by the RFP. Protest at 7; Comments at 1-2. The firm also argues that, even if the evaluation had properly assessed its experience as providing low confidence, the RFP did not permit that evaluation alone to be the basis for rejecting Core's proposal; instead, the RFP required the VA to determine that Core's proposal was also technically unacceptable before rejecting it. We consider both arguments and find that neither provides a basis for our Office to sustain the protest.

Experience Evaluation

As background to Core's challenges to the evaluation of its experience, we summarize the evaluation of all three experience references under the first subfactor, relevance. For the remaining experience subfactors, although we have reviewed all of Core's challenges, we only discuss one example for each subfactor.

Under the relevance subfactor, the evaluators determined that Core's first experience reference involved the performance of telephone help desk services that were not comparable to the VA's requirement because the work involved 8,093 contacts annually, handled by six employees, which was significantly lower than the 1.6 million calls and 312 agents required by the RFP, and the subject matter did not involve “high-sensitivity service environments or vulnerable populations.” AR, Tab 8, Experience Evaluation Report for Core at 2. Core's second experience reference, which involved performance by its proposed subcontractor, involved handling calls to trace firearms used in crimes. The evaluation recognized that the contract involved a highly-sensitive environment, but the evaluators found that the call volume of 567,000 calls annually that were handled by 200 agents was significantly lower than the RFP requirement, and the callers were not from vulnerable populations, both of which made the experience not comparable to the RFP. Id. at 3. For its third experience reference, also performed by Core's proposed subcontractor, the proposal identified work supporting a military treatment facility call center. Although the third reference showed work in a highly-sensitive environment and involved vulnerable populations, it involved no more than 1.2 million calls annually and 137 agents, which the evaluators concluded were significantly lower than the VA's requirement and, thus, made the third reference not comparable to the RFP. Id.

Under the role and scope of work subfactor, the evaluators determined, for example, that the performance metrics used to measure Core's work under its first reference contract were “first contact resolution rate, agent attitude, quality, and timeliness.” Id. at 3. However, the evaluators determined that those metrics were not aligned with the performance metrics under the RFP, which were to measure the contractor's “average speed to answer, schedule adherence, [incoming call] abandonment rate, and call quality evaluation.” Id. The evaluators determined that those differences constituted a misalignment that served to lower the agency's confidence in Core's performance of the contract at issue. Id. For the firm's second and third references, the evaluators noted similar distinguishing characteristics that lowered the agency's confidence in Core's ability to perform the VEOCC contract. Id.

Under the complexity and operational scale subfactor, the evaluation determined, for example, that Core's second contract showed that the firm's efforts had an inbound call volume of 567,000 annually--significantly lower than the 1.6 million calls under the VEOCC requirement--and the proposal also did not provide clear information on the hours of operation under the contract, so the evaluators could not compare them to the VEOCC requirement for 24/7/365 operation. The evaluators concluded that the differences between the VEOCC requirement and each of Core's three experience contracts in their complexity and operational scale lowered the agency's confidence in the firm's ability to meet the agency's requirements. Id. at 5.

Finally, under the recency and duration subfactor, the evaluation did not discuss each of Core's contracts individually but, rather, summarized the evaluators' determination that each of Core's experiences was both recent and of sufficient duration to meet the agency's criteria and support “confidence in the continuity of their operational experience.” Id.

Core's challenges to the experience evaluation primarily argue that the above evaluation was inconsistent with the RFP's terms. The firm contends that the VA impermissibly assessed each experience example as a discrete item and “repeatedly faulted each one for not independently matching every material feature of the current requirement.” Protest at 8. The firm argues that the RFP required the VA to make an aggregated assessment of all an offeror's experience examples as a whole, which it argues would have shown that the experience of Core and its proposed subcontractor bore significant similarity and, thus, relevance to the RFP requirements. Id. at 5-7; Comments at 2. For example, Core contends that by adding the calls handled in its second and third experience examples, the firm's experience showed the ability to handle 2,867,000 calls, which significantly exceeded the 1.6 million incoming calls of the VEOCC requirement. Comments at 2. Similarly, the firm argues that, when combined, its references also showed experience in performing similar services in high-sensitivity environments, servicing vulnerable populations, and handling contacts under 24/7/365 performance requirements. Id. at 1.

The VA argues that the RFP did not provide for the aggregation of distinct experience references, that it had the discretion to assess each reference separately, and that the evaluation of each reference was reasonable and consistent with the RFP. Memorandum of Law (MOL) at 3. The result of that evaluation, the agency contends, reasonably determined that none of Core's experience references demonstrated that Core had similar experience performing relevant services for the volume and scope that the RFP required. Id. at 5. The agency contends that the assessment of a low confidence rating was based on clear differences between the agency's requirement and Core's experience record and was a reasonable evaluation judgment. Id. at 7.

Where a solicitation provides for the evaluation of an offeror's experience, the agency has broad discretion to determine the extent to which a particular reference contract is relevant to the agency's requirement. A&D Gen. Contracting, Inc., B-409429, Apr. 17, 2014, at 2. Where a protester challenges the evaluation of its experience, our Office will examine the evaluation record to determine whether the agency's judgments were reasonable and consistent with the solicitation. Id. Our review recognizes that the evaluation of experience involves subjective judgments, so we will not substitute our judgment for the agency's reasonably-based evaluation ratings. Obayashi-JPS JV, B‑407792, Jan. 29, 2013, at 3.

Our review of the record supports the reasonableness of the agency's evaluation. Contrary to the protester's assertion, the RFP did not require the VA to treat the three experience references in an offeror's proposal as if they were a single effort in assessing the extent to which that experience corresponded to the VEOCC requirements; instead, the RFP provided only that a single confidence rating would be assessed for the experience factor. Determining that single rating by assessing each experience reference separately was thus consistent with the RFP. Nor does the record show that the agency's judgments in evaluating Core's references were unreasonable. Rather, the VA compared aspects of each reference to the requirements of the RFP under each subfactor and, under all but one subfactor, found that each of the experiences Core described was different from the RFP in significant respects, such as involving lower volumes of incoming calls,[1] lacking interaction with sensitive populations, measuring performance by different metrics, or providing services less than the 24/7/365 requirement of the VEOCC. Those differences reasonably support the agency's evaluation judgment that Core's experience lowered confidence in the firm's ability to perform the RFP requirement and, in combination, supported a rating of low confidence under the experience factor. Accordingly, the record provides no basis to sustain Core's challenges to the evaluation of its proposal under the experience factor.

Elimination of Proposal from Evaluation and Award

Next, Core argues that even if its proposal was properly evaluated under the experience factor, the VA lacked a valid basis to eliminate the proposal from consideration based solely on that evaluation. Core acknowledges that where a proposal was rated low confidence under the experience factor, the RFP provided that the VA “reserve[d] the right to cease further evaluation and remove the Offeror from consideration for award.” RFP amend. 2 at 194. However, Core argues that the VA could eliminate the proposal only if it was also evaluated as technically unacceptable. Protest at 6. Core contends that the VA only had the discretion to eliminate Core's proposal from consideration if the low confidence rating “resulted from a VA conclusion that [Core's] proposal was technically unacceptable.” Protest at 6. Otherwise, the protester contends that the VA was required to evaluate the proposal under the remaining factors and consider it--and in particular, its lower price--when making the source selection decision. Comments at 5.

The VA argues that in eliminating Core's proposal from consideration after making a reasonable assessment of the firm's experience and determining that it provided low confidence that the firm would be able to successfully perform the VEOCC requirements, the agency was acting consistent with the express terms of the RFP.

When reviewing an agency's rejection of a proposal as noncompliant, our Office will examine the record to determine whether the agency's decision was reasonable and in accordance with the solicitation criteria and applicable statutes and regulations. Global Dimensions, LLC, B-419672, May 12, 2021, at 3. A clearly-stated solicitation requirement is considered material to the needs of the government, so a proposal that fails to conform may be rejected as unacceptable. Hurricane Consulting, Inc., B-423839 et al., Jan. 2, 2026, at 8 (agency properly rejected proposal that did not meet personnel experience requirements).

Here, although the protester correctly notes that the evaluation did not conclude that Core's proposal was unacceptable under the technical factor, under the terms of this RFP, the evaluation of the firm's experience as justifying a rating of low confidence was sufficient to support the VA's decision to eliminate the proposal from further evaluation and, ultimately, from being considered for award. The RFP described the result of being assessed a rating of low confidence or no confidence as sufficient a basis to “cease further evaluation and remove the Offeror from consideration for award.” RFP at 194-95. The provision that followed explained a limited circumstance where that result would not follow: in a case where all proposals had received a low confidence or no confidence rating in at least one non-price evaluation factor. Rather than eliminating all proposals, the agency could hold discussions with those offerors that had been rated some confidence or higher under at least one factor. Id. Otherwise, as here, the RFP provided that a low confidence rating would justify eliminating an offeror's proposal from the competition. In effect, the RFP imposed a material requirement that offerors demonstrate experience sufficient to attain a rating of some confidence or higher.

As a result, even though Core's proposal was not otherwise unacceptable, it was subject to elimination from the competition under the terms of the RFP for failing to demonstrate experience justifying a rating of some confidence or higher. As discussed above, Core's experience lowered the evaluators' confidence in its ability to perform the VEOCC requirement successfully, which reasonably resulted in a low confidence rating under that factor. The VA's rejection of Core's proposal based on its evaluation of low confidence under the experience factor was both reasonable and consistent with the express terms of the RFP.

The protest is denied.

Edda Emmanuelli Perez
General Counsel