Protester Argued There Was No Basis for Corrective Action. GAO Disagreed

The protester challenged the agency’s proposed corrective action to add a price realism provision to the solicitation. It argued that there was no basis to do so because price realism had not been raised in prior protests. GAO ruled that adding such a provision was within the agency’s discretion.

Catalyst Solutions, LLC, GAO B-423269.2

• Protest – The protester challenged the issuance of a task order for program management support services. Specifically, it objected to the scope of the agency’s proposed corrective action. It claimed it was unreasonable to amend the solicitation to include a provision for price realism because, in the protester’s prior protest, it did not allege the agency failed to evaluate proposals for realism. This meant the agency could not justify this aspect of the proposed corrective action.
• Decision – GAO found no basis to sustain a protest. It was the agency’s discretion to include a provision for price realism as part of its corrective action. GAO refused to disturb this when the protester did not demonstrate the agency’s judgment was unreasonable. Thus, the protest was denied.

The protester was represented by Milton C. Johns of Executive Law Partners, PLLC. The agency was represented by Jared M. Miller and Lisa L. Baker of the United States Marine Corps. Paula A. Williams and Evan D. Wesser of GAO participated in the preparation of the decision.

— Case summary by Joshua Lim, Assistant Editor.

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