Agency Unreasonably Eliminated Proposal Based on Compliance with Proposal Preparation Instructions, Instead of Evaluation of Substance; GAO B-414787, McCann-Erickson USA Inc.

Protest challenging the agency’s elimination of a proposal from further consideration is sustained, where the agency’s decision was based on a perfunctory review of the proposal’s compliance with preparation instructions, not on an evaluation of the proposal’s substance, and where the solicitation did not provide that the agency would conduct such a strict, pass/fail review.