Protester Submitted Same Proposal It Used in an Earlier Procurement. Did the Agency Err in Rating the Proposal Lower the Second Time Around?
The protester challenged its ratings. The protester reasoned it had submitted the same proposal in a previous procurement and received higher ratings. GAO said ratings from a previous procurement were irrelevant.
Royal Bridge, Inc., GAO B-422263
- Protest Argument – The protester challenged the ratings it received under technical and organizational factors. The protester noted it had submitted an almost identical proposal in a different 2020 procurement. That proposal received higher ratings.
- Evaluation Was Reasonable – GAO rejected the protester’s argument. The protester’s reliance on a previous evaluation conducted by a different evaluation team on a prior procurement did not demonstrate that the current evaluation was unreasonable. Each procurement stands on its own. The evaluation under one solicitation is not probative in an evaluation under another.
The protester is represented by S. Leo Arnold of Ashley & Arnold. The awardee is represented by Keith Beardon of McCormick Industrial Abatement Services. The agency is represented by Tarrah M. Beavin, Ronald Goodeyon, Cristy Park, and Skye Martin of the Army. GAO attorneys Suresh S. Boodram and Evan D. Wesser participated in the decision.
Case summary by Craig LaChance, Senior Editor
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